https://www.taxtmi.com/caselaws?id=62581 A transaction structured with retained control, revocation rights and no transfer of interest in property was treated as a licence and sub-licences, not a lease or sub-lease. Refundable deposits received for allotment of space, being returnable on termination and supported by a real refund obligation, were held not to be trading receipts or taxable income merely because they were interest-free or retained during the arrangement. Interest under section 217 was also held not leviable where there was no advance-tax liability on the assessed or returned income basis. The stated principle is that taxability depends on the true nature of the transaction, not its description. en-us Mon, 17 Apr 1995 00:00:00 +0530 Thu, 20 Jan 2011 15:33:24 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=62581 A transaction structured with retained control, revocation rights and no transfer of interest in property was treated as a licence and sub-licences, not a lease or sub-lease. Refundable deposits received for allotment of space, being returnable on termination and supported by a real refund obligation, were held not to be trading receipts or taxable income merely because they were interest-free or retained during the arrangement. Interest under section 217 was also held not leviable where there was no advance-tax liability on the assessed or returned income basis. The stated principle is that taxability depends on the true nature of the transaction, not its description. Case-Laws Income Tax Mon, 17 Apr 1995 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=62581