Temporary Factory Letting Doesn’t End Business: ITAT Holds User Charges as Business Income

Rayat Sahakari Sakhar Karkhana Ltd. Vs ITO (ITAT Pune) Temporary Letting ≠ End of Business: User Charges Are Business Receipts – ITAT Holds Sugar Factory Income as Business Income Assessee-sugar factory had temporarily handed over crushing operations to Sahu SSK under a collaboration agreement dated 27.08.2009, receiving user charges linked to MT crushed. AO treated these receipts as “Income from Other Sources”, held that Assessee had ceased business, & denied set-off of brought-forward losses of ₹26,86,106. CIT(A)-NFAC upheld the view, treating activity as passive income. Tr...