Cross country pipeline classification and ITC entitlement: pipelines outside factory treated as immovable, ITC disallowed under Section 17 restriction...
Characterisation of receipts turned on the nature of the assessee's activities and services, not mere ownership or leases; where letting is accompanied by systematic provision of amenities and operational facilities, such receipts constitute income from business or profession. Reliance on Supreme Court precedents applying the nature of activity test supported treating rental receipts as business income. Prior assessments accepting the same treatment invoked the principle of consistency, reinforcing classification as business income rather than income from house property. Decision went against the revenue.
Characterisation of receipts turned on the nature of the assessee's activities and services, not mere ownership or leases; where letting is accompanied by systematic provision of amenities and operational facilities, such receipts constitute income from business or profession. Reliance on Supreme Court precedents applying the nature of activity test supported treating rental receipts as business income. Prior assessments accepting the same treatment invoked the principle of consistency, reinforcing classification as business income rather than income from house property. Decision went against the revenue.
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