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The ITAT remanded the matter to the AO for verification of the assessee's claim that rental income belongs to the Trust, as the assessee failed to provide conclusive evidence of property ownership by the Trust for the relevant assessment year. Although the rental income was initially reported under the assessee's PAN and later revised to the Trust's PAN, mere credit of rent to the Trust's bank account and a rental agreement unrelated to the assessment year were insufficient to establish the Trust's ownership or income liability. The AO is directed to examine any further evidence submitted by the assessee to prove ownership or income inclusion in the Trust's return. If established, the AO shall delete the addition of rental income in the assessee's hands. The appeal is allowed for statistical purposes and the case remanded for fresh adjudication.
The ITAT remanded the matter to the AO for verification of the assessee's claim that rental income belongs to the Trust, as the assessee failed to provide conclusive evidence of property ownership by the Trust for the relevant assessment year. Although the rental income was initially reported under the assessee's PAN and later revised to the Trust's PAN, mere credit of rent to the Trust's bank account and a rental agreement unrelated to the assessment year were insufficient to establish the Trust's ownership or income liability. The AO is directed to examine any further evidence submitted by the assessee to prove ownership or income inclusion in the Trust's return. If established, the AO shall delete the addition of rental income in the assessee's hands. The appeal is allowed for statistical purposes and the case remanded for fresh adjudication.
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