Contract construction confirmed ownership of plant and machinery, with lease rentals treated as taxable revenue receipt and accrued income.

On construction of the agreements, the assessee was treated as having become the owner of the plant and machinery, and the lease rentals were held to be taxable as revenue receipt and accrued income. The Court found no reason to interfere with the High Court's conclusion sustaining taxability, and the appeal was dismissed.

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Issues: Whether, on construction of the agreements, the respondent-assessee became the owner of the plant and machinery and whether the lease rentals were taxable as revenue receipt and accrued income.

Analysis: The agreements were construed to show that the respondent-assessee had become the owner of the plant and machinery. It was also noted that the lease rentals in entirety had already been taxed as revenue receipt and as income accrued and taxable. No reason was found to interfere with the High Court's final conclusion.

Conclusion: The findings of the High Court were upheld and the appeal was dismissed.

Ratio Decidendi: Where the contractual clauses show that the assessee has become the owner of the plant and machinery, and the lease rentals are treated as revenue receipt and accrued income, no interference is warranted with the finding sustaining taxability.

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