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Issues: Whether rental income from a flat in a multi-storeyed building is assessable under the head "Income from house property" even though the assessee had not obtained legal title through a registered sale deed.
Analysis: The issue was governed by the principle that, for the purposes of section 22 of the Income-tax Act, 1961, ownership is not confined to legal title evidenced by registration. A person who has paid the full consideration and been put in possession is treated as the owner for taxing the income from the property in his or her own right. The requirement of a registered sale deed under section 54 of the Transfer of Property Act does not control the meaning of "owner" in this context.
Conclusion: The rental income is assessable under the head "Income from house property" notwithstanding the absence of a registered sale deed, and the question was answered in favour of the assessee.