Rental Income Can’t Be Reclassified as Business Profits based on Consistency Rule: ITAT Mumbai

H&M Housing Finance and Leasing Private Limited Vs DCIT (ITAT Mumbai) AO Can’t Reclassify Rent as Business Income- Consistency Rule Applied – ITAT Mumbai Deletes Business Head Taxing of Rent Facts: Assessee, a leasing & finance company, owned a commercial property (Raheja Woods, Pune) let out to HSBC Software Development Pvt. Ltd. under a long-term lease (2015–2024). Rental income of ₹10.62 Cr was offered as Income from House Property with deduction u/s 24. AO taxed it as Business Income, applying SC ruling in Chennai Properties & Investments Ltd., thereby denying deductio...