https://www.taxtmi.com/caselaws?id=38830 Income from the Khedgalli property was assessable under section 9 of the Indian Income-tax Act, 1922 only if the assessee-company was the owner of the building. The revenue failed to establish such ownership: the land belonged to the assessee, but the building was constructed at the cost of prospective flat purchasers and was not shown to have initially vested in the assessee or the licensees. An unregistered licence, an unregistered consent decree, or later leases could not convey title; at most, the leases created estoppel. Section 108(h) of the Transfer of Property Act, 1882 did not assist because it applies to leases, not licences. Accordingly, the income was not assessable under section 9. en-us Fri, 19 Dec 1975 00:00:00 +0530 Fri, 09 Apr 2010 12:39:31 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=38830 Income from the Khedgalli property was assessable under section 9 of the Indian Income-tax Act, 1922 only if the assessee-company was the owner of the building. The revenue failed to establish such ownership: the land belonged to the assessee, but the building was constructed at the cost of prospective flat purchasers and was not shown to have initially vested in the assessee or the licensees. An unregistered licence, an unregistered consent decree, or later leases could not convey title; at most, the leases created estoppel. Section 108(h) of the Transfer of Property Act, 1882 did not assist because it applies to leases, not licences. Accordingly, the income was not assessable under section 9. Case-Laws Income Tax Fri, 19 Dec 1975 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=38830