Organised provision of specialised facilities and services can generate business income, not income from other sources.

Receipts from running an auditorium and providing air-conditioning and related facilities were held to be assessable as business income because the activity was organised, commercial, and carried on with the object of earning profit. The court treated the residuary head of income from other sources as applicable only where the income could not fit under an earlier head. On the facts, the auditorium was not a bare letting of property, and the services involved specialised equipment, staff, maintenance, supervision, and auxiliary facilities, showing a business operation rather than passive ownership income.

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Issues: Whether the income derived from running the auditorium and providing air-conditioning services to tenants was chargeable under the head "Business" or under the head "Other sources".

Analysis: The definition of "business" under the Income-tax Act, 1961 is wide enough to include an activity carried on with the object of earning income by providing specialised services and facilities. The head "Income from other sources" is residuary and applies only when the income cannot be brought under any earlier head. On the facts, the auditorium was not a bare letting of property, and the air-conditioning service was not a mere incidental amenity attached to ownership of the building. Both activities involved specialised equipment, substantial staff, maintenance, supervision, and provision of auxiliary services such as equipment, canteen, and related facilities, all of which showed a commercial and organised activity.

Conclusion: The income from the auditorium and the air-conditioning services was business income and not income from other sources, and the determination was in favour of the assessee.

Ratio Decidendi: Where a taxpayer carries on an organised commercial activity by providing specialised facilities and services with the object of earning profit, the resulting receipts are assessable as business income and do not fall under the residuary head of income from other sources.

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