https://www.taxtmi.com/caselaws?id=8652 Rent from a studio building was assessable as income from property, not as business income, because the film-production business had been discontinued, the machinery used in that business had been sold, and the building was let out as a cotton godown. The heads of income are mutually exclusive, so a receipt falling specifically under the property head cannot be shifted to business income merely because the company's objects permitted letting of assets or because an earlier assessment had treated similar receipts differently. The decisive test was whether the letting represented exploitation of property as owner rather than use in an ongoing business; on these facts, the income arose only from ownership of the building. en-us Wed, 16 Aug 1972 00:00:00 +0530 Sat, 09 May 2009 19:08:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=8652 Rent from a studio building was assessable as income from property, not as business income, because the film-production business had been discontinued, the machinery used in that business had been sold, and the building was let out as a cotton godown. The heads of income are mutually exclusive, so a receipt falling specifically under the property head cannot be shifted to business income merely because the company's objects permitted letting of assets or because an earlier assessment had treated similar receipts differently. The decisive test was whether the letting represented exploitation of property as owner rather than use in an ongoing business; on these facts, the income arose only from ownership of the building. Case-Laws Income Tax Wed, 16 Aug 1972 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=8652