https://www.taxtmi.com/highlights?id=98346 The ITAT held that where contemporaneous accounts, receipts and audited records showed the premises was actively used for the assessee's business during the year, the property fell outside section 22 and the deeming fiction for annual letting value under section 23 did not apply. Receipts linked to school operations and later tax treatment of advance educational collections supported the business-use explanation, which the Revenue did not rebut. It also found the Assessing Officer's notional valuation at a percentage of cost to be arbitrary, so the addition for deemed rental income was deleted and the Revenue's appeal dismissed; the reopening challenge in cross-objection was left open as academic. en-us Thu, 02 Apr 2026 08:50:44 +0530 Thu, 02 Apr 2026 08:50:46 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=98346 The ITAT held that where contemporaneous accounts, receipts and audited records showed the premises was actively used for the assessee's business during the year, the property fell outside section 22 and the deeming fiction for annual letting value under section 23 did not apply. Receipts linked to school operations and later tax treatment of advance educational collections supported the business-use explanation, which the Revenue did not rebut. It also found the Assessing Officer's notional valuation at a percentage of cost to be arbitrary, so the addition for deemed rental income was deleted and the Revenue's appeal dismissed; the reopening challenge in cross-objection was left open as academic. Highlights Income Tax Thu, 02 Apr 2026 08:50:44 +0530 https://www.taxtmi.com/highlights?id=98346