2025 (1) TMI 1056

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....ting of deduction u/s 24(a) to Rs. 1,97,80,200/- as claimed by the assessee by computing the income from house property and in the intimation u/s. 143(1)(a) the assessee's income was assessed at Rs. 6,69,38,890/- as against "Nil" income by treating the income from house property as business income; Secondly, non granting of credit for TDS deducted from house property. 3. The brief facts of the case are that the assessee is a private specified beneficiary trust registered on 25.11.1978 for the benefit of 5 beneficiaries each having 20% share of income. The income derived from the trust has been offered to tax by the beneficiaries in their respective return of income in their individual hands. The assessee trust filed a return of income fo....

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....), it is seen that assessee is a private specified trust which had a property and was let out without any other asset or rendering any kind of services to M/s Schlumberger Asia Ltd. in the year 2003. The property continued to be rented till date and during the year assessee trust received rent of Rs. 6,59,34,000/-. Since assessee being the owner of the property which was given on rent without any service or any other amenities, therefore, the rent received was declared under the head income from house property and such "income from house property" has been shown in all the earlier years, and there was never any dispute by the department. It is well settled principle, in view of the judgment of Hon'ble Supreme Court in the case of Raj Dadark....