https://www.taxtmi.com/caselaws?id=5038 Income from specially constructed film vaults with attendant services was treated as business income because the receipts arose from a commercial undertaking, not merely from ownership of property. The court noted that the income-tax heads in section 6 of the Indian Income-tax Act, 1922 are mutually exclusive and that the true character of the receipts depends on the real nature of the activity. The vaults were fire-proof, access was controlled, the assessee retained the key, and additional services such as fire alarms, railway booking, canteen, telephone facilities and staff support were provided. The arrangements were licences rather than leases, so the income fell under section 10, not section 9. en-us Wed, 26 Apr 1967 00:00:00 +0530 Tue, 18 Nov 2008 00:00:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=5038 Income from specially constructed film vaults with attendant services was treated as business income because the receipts arose from a commercial undertaking, not merely from ownership of property. The court noted that the income-tax heads in section 6 of the Indian Income-tax Act, 1922 are mutually exclusive and that the true character of the receipts depends on the real nature of the activity. The vaults were fire-proof, access was controlled, the assessee retained the key, and additional services such as fire alarms, railway booking, canteen, telephone facilities and staff support were provided. The arrangements were licences rather than leases, so the income fell under section 10, not section 9. Case-Laws Income Tax Wed, 26 Apr 1967 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=5038