https://www.taxtmi.com/caselaws?id=71238 The Tribunal dismissed the revenue's appeals, affirming the treatment of warehousing income as business income. It emphasized the organized trade nature of the assessee's activities, providing additional services beyond mere property rental. The Tribunal upheld the principle of consistency, noting prior assessments treated the income as business income, and rejected the Assessing Officer's reclassification without material change in facts. The judgment underscored assessing income based on commercial exploitation rather than property attachment. The technical aspect of reopening under section 147 was deemed unnecessary, as the issue was resolved on its merits. en-us Fri, 30 Dec 2005 00:00:00 +0530 Wed, 27 Mar 2024 15:23:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=71238 The Tribunal dismissed the revenue's appeals, affirming the treatment of warehousing income as business income. It emphasized the organized trade nature of the assessee's activities, providing additional services beyond mere property rental. The Tribunal upheld the principle of consistency, noting prior assessments treated the income as business income, and rejected the Assessing Officer's reclassification without material change in facts. The judgment underscored assessing income based on commercial exploitation rather than property attachment. The technical aspect of reopening under section 147 was deemed unnecessary, as the issue was resolved on its merits. Case-Laws Income Tax Fri, 30 Dec 2005 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=71238