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Correct head of income - surplus arising from the transfer and assignment of right, title and interest in the agreements for acquisition of office premises - Tribunal has considered the business reality and found that the two office premises by the Appellant-Assessee were acquired with an intention to resell and not for use. - Having found no perversity in the approach of the Tribunal and its conclusion, the first question of law framed will have to be answered against the Appellant–Assessee - HC