https://www.taxtmi.com/caselaws?id=177812 Amounts received upfront for granting long-term leasehold rights and transfer permissions were treated in substance as premium or salami, not advance rent, because the consideration was lump-sum, the term ran for 60 years, there was no real rent-adjustment mechanism, no refund obligation existed, and the activity was carried on as an organised real estate venture; the receipts were therefore assessable as business income. Section 11 exemption was denied because registration under section 12A did not by itself establish entitlement, the claimed scientific research or charitable purpose was not substantially pursued, the activity was predominantly commercial, separate books were not maintained for the business activity, section 11(4A) conditions were not met, and the accounts did not show proper application or accumulation of income for charitable purposes. en-us Thu, 29 Nov 2001 00:00:00 +0530 Tue, 19 Jan 2016 17:12:50 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=177812 Amounts received upfront for granting long-term leasehold rights and transfer permissions were treated in substance as premium or salami, not advance rent, because the consideration was lump-sum, the term ran for 60 years, there was no real rent-adjustment mechanism, no refund obligation existed, and the activity was carried on as an organised real estate venture; the receipts were therefore assessable as business income. Section 11 exemption was denied because registration under section 12A did not by itself establish entitlement, the claimed scientific research or charitable purpose was not substantially pursued, the activity was predominantly commercial, separate books were not maintained for the business activity, section 11(4A) conditions were not met, and the accounts did not show proper application or accumulation of income for charitable purposes. Case-Laws Income Tax Thu, 29 Nov 2001 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=177812