https://www.taxtmi.com/caselaws?id=61808 An agreement for sale did not transfer ownership or confer any right to the rents and profits of the property, so the assessee was not the landlord. Although tenant collections were rent in the vendor's hands, amounts passed on to the assessee were not rent in the assessee's hands. The arrangement also involved an element of mortgage by deposit of title deeds, and the payments represented the commercial return for use of the advance, not income from property. Applying the substance-over-form principle, the receipts were treated as the commercial equivalent of interest and assessable under the head "Income from other sources". en-us Fri, 30 Nov 1990 00:00:00 +0530 Sat, 15 Jan 2011 11:33:13 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=61808 An agreement for sale did not transfer ownership or confer any right to the rents and profits of the property, so the assessee was not the landlord. Although tenant collections were rent in the vendor's hands, amounts passed on to the assessee were not rent in the assessee's hands. The arrangement also involved an element of mortgage by deposit of title deeds, and the payments represented the commercial return for use of the advance, not income from property. Applying the substance-over-form principle, the receipts were treated as the commercial equivalent of interest and assessable under the head "Income from other sources". Case-Laws Income Tax Fri, 30 Nov 1990 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=61808