Tax treatment of tenancy-right surrender receipts followed earlier year consistency, with the issue left open for regular hearing.

Amount received on surrender of tenancy rights was examined as a possible casual and non-recurring receipt under the Income-tax Act. The Tribunal had treated the receipt as exempt by following its earlier view for the assessee's prior assessment year, noting that the relevant facts had not changed and the Revenue did not dispute that position. The Court recorded that the similar claim had attained finality for the earlier year and found no apparent error in the Tribunal's approach on the issue framed for admission. The appeal was admitted and listed for regular hearing; the issue was not finally decided in this order.

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Issues: Whether the amount received on surrender of tenancy rights was a casual and non-recurring receipt under section 10(3) of the Income-tax Act, 1961, and whether the Tribunal was justified in following its earlier view for an earlier assessment year.

Analysis: The Tribunal had treated the receipt as exempt by relying on its earlier order for the assessee's prior assessment year and on the absence of any change in the relevant facts. The Revenue did not dispute the factual position noted by the Tribunal. The Court accepted, at this stage, that a similar claim had attained finality and that no error was apparent in the Tribunal's approach on the issue framed for admission.

Outcome: The appeal was admitted and directed to be listed for hearing in the regular course, with the issue noted above not finally decided in this order.

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