Income from house property is chargeable to the owner, while a tenant that merely sub-lets leased premises is not treated as a deemed owner. Where leased commercial premises are systematically exploited through sub-letting coupled with maintenance, security, cleaning and related facilities, the receipts arise from commercial exploitation of leasehold rights rather than property ownership. Their character depends on the nature of that activity, not on the taxpayer's separate salary income. Such receipts are assessable as profits and gains of business or profession and should be computed under that head.
Income from house property is chargeable to the owner, while a tenant that merely sub-lets leased premises is not treated as a deemed owner. Where leased commercial premises are systematically exploited through sub-letting coupled with maintenance, security, cleaning and related facilities, the receipts arise from commercial exploitation of leasehold rights rather than property ownership. Their character depends on the nature of that activity, not on the taxpayer's separate salary income. Such receipts are assessable as profits and gains of business or profession and should be computed under that head.
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