House property income applies to cinema building receipts under a management arrangement, not income from other sources.

Receipts from an operation and management arrangement for a cinema building were assessable as income from house property because the agreement, read as a whole, showed consideration for use of the property rather than a business venture. The occupier independently ran the multiplex, and the arrangement did not create a partnership, joint venture, or franchise relationship. As the earlier assessments had accepted the same character of income and there was no material change in facts, a different view was unwarranted. The receipts were therefore taxable under the house property head and not as income from other sources, and the Revenue's appeal failed.

---

---

Issues: Whether the receipts from the operation and management agreement with PVR Ltd. were taxable as income from house property or as income from other sources.

Analysis: The receipts arose from letting out the cinema building under an arrangement under which PVR Ltd. took over the building and independently ran the multiplex business. The earlier assessments had accepted the same character of income, and there was no material change in facts to justify a different view. The agreement, read as a whole, showed that the consideration was for use of the property and not for sharing business profits or creating a partnership, joint venture, or franchise arrangement. Rent derived from property has to be assessed under the specific head applicable to house property.

Conclusion: The receipts were rightly assessable as income from house property and not as income from other sources; the Revenue's appeal was dismissed.

Ratio Decidendi: Where the factual matrix is unchanged and a building is let for consideration under an arrangement that does not amount to a business venture, the rental receipts must be assessed under the head income from house property, and departure from the earlier view requires cogent material.

---