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    <title>2012 (11) TMI 671 - MADRAS HIGH COURT</title>
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    <description>Lease rentals from modules let out with infrastructural facilities in a software technology park were taxable as business income because the assessee&#039;s memorandum showed a main object of providing facilities for computer centres and related software activity. The modules were not passively let as bare property; they were constructed and exploited as part of the company&#039;s commercial business model. Applying the settled test that the character of letting income depends on the nature of the activity and the assessee&#039;s object, the receipts were treated as commercial exploitation of a business asset. The Revenue&#039;s appeals failed, and the Tribunal&#039;s view was affirmed.</description>
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    <pubDate>Tue, 09 Oct 2012 00:00:00 +0530</pubDate>
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      <link>https://www.taxtmi.com/caselaws?id=218656</link>
      <description>Lease rentals from modules let out with infrastructural facilities in a software technology park were taxable as business income because the assessee&#039;s memorandum showed a main object of providing facilities for computer centres and related software activity. The modules were not passively let as bare property; they were constructed and exploited as part of the company&#039;s commercial business model. Applying the settled test that the character of letting income depends on the nature of the activity and the assessee&#039;s object, the receipts were treated as commercial exploitation of a business asset. The Revenue&#039;s appeals failed, and the Tribunal&#039;s view was affirmed.</description>
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