Rayala Corporation Pvt. Ltd. v. ACIT

386 ITR 500Supreme Court of India2016#1268 most cited

What is Rayala Corporation Pvt. Ltd. v. ACIT authority for?

If an assessee company's main business object is to acquire and rent out properties, the rental income derived is taxable as 'Profits and gains of business or profession', rather than 'Income from house property', as the nature of the activity constitutes a business.

89

judgments rely on this decision, according to BharatTax’s citation analysis of 366,470 Indian tax judgments — from 2011 to 2025.

Also referred to as

Rayala Corporation Pvt. Ltd. v. ACIT · 386 ITR 500 · SC 2016 · rental income classification · business income vs house property · section 22 · section 23 · section 24 · profits and gains of business or profession · main object of business · property letting business · nature of activity assessee

Sections most often in play

Section 143(3)Section 24Section 119Section 139Section 143(1)Section 143(2)Section 14ASection 194-I
Read the full judgment

Issues it is cited on

section 23(1)(a)annual valuesection 23(1)house property incomesection 24(a)maximum marginal rateprofits and gains of business or professionmiscellaneous applicationsection 22section 24section 23unexplained expenditure

Judgments citing Rayala Corporation Pvt. Ltd. v. ACIT

Rak Construction Project Ltd., Mumbai vs. ITO 3 (3)(1), Mumbai

ITA 7584/MUM/2019[2010-11]Status: DisposedITAT Mumbai13 Jul 2020AY 2010-11

Bench: Shri Saktijit Deyand Shri Manoj Kumar Aggarwal

For Appellant: Shri Bhupendra ShahFor Respondent: Smt. Jyothilakshmi Nayak
Section 143(1)Section 147Section 271(1)(c)

…s rightly set–off against work–in–progress. In support of his contention, the learned Counsel relied upon the following decisions:– i) Chennai Properties& Investments Ltd. v/s CIT, [2015] 373 ITR 673 (SC); and ii) Rayala Corporation Pvt. Ltd. v/s ACIT, [2016]386 ITR 500 (SC). 7. The learned Authorised Representative further submitted that the compensation received by the assessee is in the nature of mesne profits received by the assessee on account of damages for deprivation and use of occupation. Hence, the compensation received is capital in nature. In support of such contention, he relied upon the following…

M/S. G G Associates, Pune vs. Deputy Commissioner of Income-Tax, Circle - 7, Pune

In the result, the appeal is allowed

ITA 1946/PUN/2017[2013-14]Status: DisposedITAT Pune07 Jul 2020AY 2013-14

Bench: Shri R. S. Syal, Vp & Shri Partha Sarathi Chaudhury, Jm आयकर अपील सं. / Ita No.1946/Pun/2017 िनधा"रण वष" / Assessment Year : 2013-14 M/S. G. G. Associates, San Mahu Complex 5, Bund Garden Road, Opp. Poona Club, Pune-411001. Pan: Aaffg5234G ……….. आवेदक/Applicant बनाम / V/S. Dcit, Circle-7, Pune. ..……""यथ" / Respondent Assessee By : Shri Krishana Gujarathi Revenue By : Shri Maruti W. Maddewad सुनवाई क" तारीख / Date Of Hearing : 03.07.2020 घोषणा क" तारीख / Date Of Pronouncement : 07.07.2020 आदेश / Order Per Partha Sarathi Chaudhury, Jm: This Appeal Preferred By The Assessee Emanates From The Order Of The Ld. Cit(Appeal), Pune-5 Dated 15.06.2017 For The Assessment Year 2013-14 As Per The Following Grounds Of Appeal On Record: “1) On The Facts & In The Circumstances Of The Case & In Law, The Honourable Cit (Appeal) - 5, Pune Erred In Confirming The Addition Made By The Learned Ao Of Rs. 1,26,000/- To The Income Of The Appellant Under The Head “Income From House Property” Being The Annual Letting Value Of The Unsold Units Lying As Stock In Trade Of The Appellant Without Appreciating The Fact That The Appellant Is Engaged In The Business Of Real Estate Development & The Unsold Flats Are Held As Stock In Trade & Not As Investment. The Appellant Hereby Prays That The Said Addition Of Rs.1,26,000/- May Please Be Deleted.

For Appellant: Shri Krishana GujarathiFor Respondent: Shri Maruti W. Maddewad
Section 23Section 23(4)

…sidering the objects of the company, the Hon’ble Supreme Court held that such income was chargeable to tax under the head “Profits and gains from business or profession”. More recently, the Hon’ble Supreme Court in Rayala Corporation Pvt. Ltd. Vs. ACIT (2016) 386 ITR 500 (SC) considered a situation in which the assessee was engaged in the business of renting its properties. The assessee claimed such rental income as falling under the head “Profits and gains of business or profession”. The AO denied such a treatment. When the matter finally came up before the Hon’ble Supreme Court, it considered both the judgments…

The ACIT, Cochin vs. M/S.Ptl Enterprises Ltd, Cochin

In the result, the appeal filed by the Revenue is dismissed

ITA 84/COCH/2020[2014-15]Status: DisposedITAT Cochin06 Jul 2020AY 2014-15

Bench: Shri Chandra Poojari, Am & Shri George George K, Jm

For Appellant: Sri.Mritunjaya Sharma, CIT-DRFor Respondent: S/Sri.Joseph Marcose, Sr.Advocate &
Section 56(2)(ii)

…diture in the instant year which has been incurred wholly and exclusively for business of the appellant company. 8.15 Furthermore, even judicially speaking the Apex Court vide judgment rendered on 11.8.2016 in the case of Rayala Corporation (P) Ltd. vs. ACIT 386 ITR 500 held where a company had only one business i.e. leasing of property and earning rent therefrom that even if letting of property is not main business as per Memorandum of Association such income should be assessed as business income and not house property. In arriving at the above conclusion, the Hon’ble Apex Court followed the judgment dated 9.4.…

M/S. Asset Investment Services, Thane vs. ITO-26(1)(2), Mumbai

In the result, appeal filed by the assessee for assessment year 2012-

ITA 332/MUM/2019[2012-13]Status: DisposedITAT Mumbai21 Apr 2020AY 2012-13
For Appellant: Shri Viraj Mehta (AR)For Respondent: Shri Michael Jerald (DR)
Section 143Section 143(3)Section 147Section 148Section 234A

…IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI BENCHES “A”, MUMBAI BEFORE SHRI RAJESH KUMAR (AM) AND SHRI RAM LAL NEGI (JM) Assessment Year: 2012-13 M/s Asset Investment Services, The ITO – 26(1)(2), Shop No. 11006, Ground Floor, Room No. 701, C-12, Bipasha CHS, Star Colony, 7th Floor, Pratyakshakar Manpada Road, Dombivli East, Vs. Bhavan, Bandra Kurla Thane - 421204 Complex, Bandra East, PAN: AAQFA7714D Mumbai - 400051 (Appellant) (Respondent) Assessee by: Shri Viraj Mehta (AR) Revenue by : Shri Michael Jerald (DR) Date of Hearing: 02/03/2020 Date of Pronouncement: 21/04/2020 O R D E R PER RAM LAL NEGI, JM This…

M/S. Asset Investment Services, Thane vs. ACIT-26(1), Mumbai

In the result, all the appeals of the assessee are allowed

ITA 331/MUM/2019[2013-14]Status: DisposedITAT Mumbai28 Jan 2020AY 2013-14

Bench: Shri R.C.Sharma

Section 143(3)Section 22

…IN THE INCOME TAX APPELLATE TRIBUNAL “SMC”, BENCH MUMBAI BEFORE SHRI R.C.SHARMA, ACCOUNTANT MEMBER ITA No. 331 /Mum/2019 (Assessment Year: 2013-14) M/s Asset Investment Vs. A.C.I.T.-26(1) Room No. 701, C-12, 7th Services, Shop No. 11006, Ground Floor, Pratyakshakar Floor, Bipasa CHS, Star Bhavan, Bandra Kurla Colony, Manpada Road, Complex, Bandra East, Dombivli East, Thane. Mumbai-400051. PAN/GIR No. AAQFA 7714 D (Appellant) .. (Respondent) ITA No. 334 & 333/Mum/2019 (Assessment Years: 2010-11 & 2011-12) M/s Asset Investment Vs. I.T.O.-26(1)(2) Room No. 701, C-12, 7th Services, Shop No. 11006, Ground Floor, Praty…

M/S. Parmar Properties Pvt.Ltd, Pune vs. Deputy Commissioner of Income-Tax, Circle - 4, Pune

Appeal are allowed

ITA 2262/PUN/2017[2013-14]Status: DisposedITAT Pune20 Jan 2020AY 2013-14

Bench: Shri Anil Chaturvedi, Am & Shri S.S. Viswanethra Raviआयकर अपीऱ सं. / Ita Nos. 2261 & 2262/Pun/2017 नििाारण वषा / Assessment Years : 2011-12 & 2013-14

For Appellant: Shri Jatin C. ShahFor Respondent: Shri Pankaj Garg
Section 143(3)Section 148Section 24

…sidering the objects of the company, the Hon‟ble Supreme Court held that such income was chargeable to tax under the head “Profits and gains from business or profession”. More recently, the Hon‟ble Supreme Court in Rayala Corporation Pvt. Ltd. Vs. ACIT (2016) 386 ITR 500 (SC) considered a situation in which the assessee was engaged in the business of renting its properties. The assessee claimed such rental income as falling under M/s. Parmar Properties Pvt. Ltd. the head “Profits and gains of business or profession”. The AO denied such a treatment. When the matter finally came up before the Hon‟ble Supreme Court…

M/S. Parmar Properties Pvt.Ltd, Pune vs. Deputy Commissioner of Income-Tax, Circle - 4, Pune

Appeal are allowed

ITA 2261/PUN/2017[2011-12]Status: DisposedITAT Pune20 Jan 2020AY 2011-12

Bench: Shri Anil Chaturvedi, Am & Shri S.S. Viswanethra Raviआयकर अपीऱ सं. / Ita Nos. 2261 & 2262/Pun/2017 नििाारण वषा / Assessment Years : 2011-12 & 2013-14

For Appellant: Shri Jatin C. ShahFor Respondent: Shri Pankaj Garg
Section 143(3)Section 148Section 24

…sidering the objects of the company, the Hon‟ble Supreme Court held that such income was chargeable to tax under the head “Profits and gains from business or profession”. More recently, the Hon‟ble Supreme Court in Rayala Corporation Pvt. Ltd. Vs. ACIT (2016) 386 ITR 500 (SC) considered a situation in which the assessee was engaged in the business of renting its properties. The assessee claimed such rental income as falling under M/s. Parmar Properties Pvt. Ltd. the head “Profits and gains of business or profession”. The AO denied such a treatment. When the matter finally came up before the Hon‟ble Supreme Court…

Dynacon Equipments Pvt Ltd., Chennai vs. ACIT Corporate Circle 1(4), Chennai

In the result, the appeal filed by assessee in ITA

ITA 2263/CHNY/2018[2009-10]Status: DisposedITAT Chennai21 Nov 2019AY 2009-10

Bench: Shri Ramit Kochar & Shri Duvvuru R.L.Reddy

For Appellant: Mr.Srinivasa Rao Vana, JCITFor Respondent: 21.11.2019
Section 143(3)Section 147Section 148

…of Profession’ , in this decision the Hon’ble Supreme Court has distinguished its own decisions in the case of Chennai Properties & Investments Ltd. v. CIT reported in (2015) 373 ITR 673(SC) and Rayala Corporation Private Limited v. ACIT reported in (2016) 386 ITR 500 (SC) to explain the parameters to be seen while bringing to tax rental income under the head ‘Income from House Property’ or under the head ‘Profit and Gains from Business or Profession’. It is observed by Hon’ble Supreme Court that facts of each case are to be seen to determine what is the correct head of income under which rental income is…

Dynacon Equipments Pvt. Ltd., Chennai vs. ACIT Corporate Circle 1(4), Chennai

In the result, the appeal filed by assessee in ITA

ITA 2172/CHNY/2018[2006-07]Status: DisposedITAT Chennai21 Nov 2019AY 2006-07

Bench: Shri Ramit Kochar & Shri Duvvuru R.L.Reddy

For Appellant: Mr.Srinivasa Rao Vana, JCITFor Respondent: 21.11.2019
Section 143(3)Section 147Section 148

…of Profession’ , in this decision the Hon’ble Supreme Court has distinguished its own decisions in the case of Chennai Properties & Investments Ltd. v. CIT reported in (2015) 373 ITR 673(SC) and Rayala Corporation Private Limited v. ACIT reported in (2016) 386 ITR 500 (SC) to explain the parameters to be seen while bringing to tax rental income under the head ‘Income from House Property’ or under the head ‘Profit and Gains from Business or Profession’. It is observed by Hon’ble Supreme Court that facts of each case are to be seen to determine what is the correct head of income under which rental income is…

M/S Jokhiram Durgadutt, Ranchi vs. DCIT Circle-1, Rnc

In the result, appeal of the assessee is dismissed

ITA 47/RAN/2018[14-15]Status: DisposedITAT Ranchi30 Aug 2019

Bench: Shri Chandra Mohan Garg, Jm & Shri L.P. Sahu, Am आयकर अपीऱ सं./Ita No.47/Ran/2018 (नििाारण वषा / Assessment Year :2014-2015) M/S Jokhiram Durgadutt, Vs. Dcit, Circle-1, Ranchi Sarawgi House, J.J.Road, Upper Bazar, Ranchi-834001 स्थायी ऱेखा सं./ जीआइआर सं./ Pan/Gir No. : Aabfj 2200 Q (अपीऱाथी /Appellant) (प्रत्यथी / Respondent) .. निर्धाऩिती की ओर से /Assessee By : Shri P.S.Paul, Ca राजस्व की ओर से /Revenue By : Shri P.K.Mondal, Addl.Cit(Dr)

For Appellant: Shri P.S.Paul, CAFor Respondent: Shri P.K.Mondal, Addl.CIT(DR)

…आयकर अपीऱीय अधिकरण, रााँची न्यायपीठ, रााँची IN THE INCOME TAX APPELLATE TRIBUNAL RANCHI BENCH, RANCHI श्री चन्द्र मोहन गगग, न्द्याययक सदस्य एवं श्री एऱ.पी.साहु, ऱेखा सदस्य के समऺ । BEFORE SHRI CHANDRA MOHAN GARG, JM AND SHRI L.P. SAHU, AM आयकर अपीऱ सं./ITA No.47/RAN/2018 (नििाारण वषा / Assessment Year :2014-2015) M/s Jokhiram Durgadutt, Vs. DCIT, Circle-1, Ranchi Sarawgi House, J.J.Road, Upper Bazar, Ranchi-834001 स्थायी ऱेखा सं./ जीआइआर सं./ PAN/GIR No. : AABFJ 2200 Q (अपीऱाथी /Appellant) (प्रत्यथी / Respondent) .. निर्धाऩिती की ओर से /Assessee by : Shri P.S.Paul, CA राजस्व की ओर से /Revenue by : Shri P.K.Monda…

M/S. Shree Balaji Ventures, Pune vs. Income-Tax Officer, Ward - 7(3), Pune

In the result, the appeal of assessee is allowed

ITA 402/PUN/2018[2014-15]Status: DisposedITAT Pune06 Aug 2019AY 2014-15

Bench: Shri D. Karunakara Rao, Am & Shri Vikas Awasthy, Jm

For Appellant: Shri Vipin GujrathiFor Respondent: Shri N. Ashok Babu
Section 23Section 23(4)

…sidering the objects of the company, the Hon’ble Supreme Court held that such income was chargeable to tax under the head “Profits and gains from business or profession”. More recently, the Hon’ble Supreme Court in Rayala Corporation Pvt. Ltd. Vs. ACIT (2016) 386 ITR 500 (SC) considered a situation in which the assessee was engaged in the business of renting its properties. The assessee claimed such rental income as falling under the head “Profits and gains of business or profession”. The AO denied such a treatment. When the matter finally came up before the Hon’ble Supreme Court, it considered both the judgments…

Cache Properties Private Limited, Hyderabad vs. Dy. Commissioner of Income Tax, Circle-1(2), Hyderabad

In the result, the appeal filed by the assessee is allowed

ITA 571/HYD/2018[2014-15]Status: DisposedITAT Hyderabad27 May 2019AY 2014-15

Bench: Smt. P. Madhavi Devi & Shri S. Rifaur Rahman

For Respondent: Smt. Neeju Gupta, DR
Section 115JSection 143(2)Section 24

…nd electricity supply amenities and the rent has been received inclusive of all the facilities. He relied upon the judgement of the Hon'ble Apex Court in the case of Sultan Brothers (P.) Ltd., Vs. CIT [51 ITR 353] (SC), Rayala Corporation (P.) Ltd., Vs. ACIT [386 ITR 500] (SC) and Chennai Properties and Investments Ltd., Vs. CIT [373 ITR 673] (SC) to hold that where the intention of assessee is to commercially exploit the property and the business of the assessee is to let out the properties, the income has to be treated as business income of the assessee. Accordingly, he brought the income declared by the assess…

The ACIT, Cochin vs. M/S.Ptl Enterprises Ltd, Cochin

In the result, the appeals filed by the Revenue are dismissed

ITA 162/COCH/2017[2013-14]Status: DisposedITAT Cochin06 May 2019AY 2013-14

Bench: Shri Chandra Poojari, Am & Shri George George K, Jm

For Appellant: Sri.Alok MitraFor Respondent: Sri.Abraham Joseph Markose
Section 56(2)(ii)

…diture in the instant year which has been incurred wholly and exclusively for business of the appellant company. 8.15 Furthermore, even judicially speaking the Apex Court vide judgment rendered on 11.8.2016 in the case of Rayala Corporation (P) Ltd. vs. ACIT 386 ITR 500 held where a company had only one business i.e. leasing of property and earning rent therefrom that even if letting of property is not main business as per Memorandum of Association such income should be assessed as business income and not house property. In arriving at the above conclusion, the Hon’ble Apex Court followed the judgment dated 9.4.…

The ACIT, Cochin vs. M/S.Ptl Enterprises Ltd, Cochin

In the result, the appeals filed by the Revenue are dismissed

ITA 161/COCH/2017[2012-13]Status: DisposedITAT Cochin06 May 2019AY 2012-13

Bench: Shri Chandra Poojari, Am & Shri George George K, Jm

For Appellant: Sri.Alok MitraFor Respondent: Sri.Abraham Joseph Markose
Section 56(2)(ii)

…diture in the instant year which has been incurred wholly and exclusively for business of the appellant company. 8.15 Furthermore, even judicially speaking the Apex Court vide judgment rendered on 11.8.2016 in the case of Rayala Corporation (P) Ltd. vs. ACIT 386 ITR 500 held where a company had only one business i.e. leasing of property and earning rent therefrom that even if letting of property is not main business as per Memorandum of Association such income should be assessed as business income and not house property. In arriving at the above conclusion, the Hon’ble Apex Court followed the judgment dated 9.4.…

The ACIT, Cochin vs. M/S.Ptl Enterprises Ltd, Cochin

In the result, the appeals filed by the Revenue are dismissed

ITA 160/COCH/2017[2011-12]Status: DisposedITAT Cochin06 May 2019AY 2011-12

Bench: Shri Chandra Poojari, Am & Shri George George K, Jm

For Appellant: Sri.Alok MitraFor Respondent: Sri.Abraham Joseph Markose
Section 56(2)(ii)

…diture in the instant year which has been incurred wholly and exclusively for business of the appellant company. 8.15 Furthermore, even judicially speaking the Apex Court vide judgment rendered on 11.8.2016 in the case of Rayala Corporation (P) Ltd. vs. ACIT 386 ITR 500 held where a company had only one business i.e. leasing of property and earning rent therefrom that even if letting of property is not main business as per Memorandum of Association such income should be assessed as business income and not house property. In arriving at the above conclusion, the Hon’ble Apex Court followed the judgment dated 9.4.…

Roxy Theatres P.Ltd, Mumbai vs. ITO 5(3)(1), Mumbai

In the result, appeals for the A

ITA 5206/MUM/2017[2009-10]Status: DisposedITAT Mumbai03 Apr 2019AY 2009-10

Bench: Shri C.N. Prasad, Hon'Ble & Shri Rajesh Kumar, Hon'Ble

For Appellant: Shri Pradeep SharmaFor Respondent: Shri Chaitanya S. Anjaria
Section 143(3)

…tore this issue to the file of the Assessing Officer to examine the issue afresh denovo, keeping in view the decisions of the Hon'ble Supreme Court in the case of Chennai Properties & Investments Ltd., v. CIT (supra) and Rayala Corporation Pvt. Ltd., v. ACIT [386 ITR 500] and thus, we restore this issue to the file of the Assessing Officer accordingly and needless to say that the Assessing Officer shall provide adequate opportunity of being heard to the assessee. 7. In the result, appeals for the A.Ys. 2009-10 and 2011-12 are dismissed as infructuous and whereas the appeal for the A.Y. 2012-13 is allowed for sta…

Roxy Theatres P.Ltd, Mumbai vs. ITO 5(3)(1), Mumbai

In the result, appeals for the A

ITA 5205/MUM/2017[2011-12]Status: DisposedITAT Mumbai03 Apr 2019AY 2011-12

Bench: Shri C.N. Prasad, Hon'Ble & Shri Rajesh Kumar, Hon'Ble

For Appellant: Shri Pradeep SharmaFor Respondent: Shri Chaitanya S. Anjaria
Section 143(3)

…tore this issue to the file of the Assessing Officer to examine the issue afresh denovo, keeping in view the decisions of the Hon'ble Supreme Court in the case of Chennai Properties & Investments Ltd., v. CIT (supra) and Rayala Corporation Pvt. Ltd., v. ACIT [386 ITR 500] and thus, we restore this issue to the file of the Assessing Officer accordingly and needless to say that the Assessing Officer shall provide adequate opportunity of being heard to the assessee. 7. In the result, appeals for the A.Ys. 2009-10 and 2011-12 are dismissed as infructuous and whereas the appeal for the A.Y. 2012-13 is allowed for sta…

Roxy Theatres P.Ltd, Mumbai vs. ITO 5(3)(1), Mumbai

In the result, appeals for the A

ITA 5204/MUM/2017[2012-13]Status: DisposedITAT Mumbai03 Apr 2019AY 2012-13

Bench: Shri C.N. Prasad, Hon'Ble & Shri Rajesh Kumar, Hon'Ble

For Appellant: Shri Pradeep SharmaFor Respondent: Shri Chaitanya S. Anjaria
Section 143(3)

…tore this issue to the file of the Assessing Officer to examine the issue afresh denovo, keeping in view the decisions of the Hon'ble Supreme Court in the case of Chennai Properties & Investments Ltd., v. CIT (supra) and Rayala Corporation Pvt. Ltd., v. ACIT [386 ITR 500] and thus, we restore this issue to the file of the Assessing Officer accordingly and needless to say that the Assessing Officer shall provide adequate opportunity of being heard to the assessee. 7. In the result, appeals for the A.Ys. 2009-10 and 2011-12 are dismissed as infructuous and whereas the appeal for the A.Y. 2012-13 is allowed for sta…

Vijay Grihnirman P. Ltd, Mumbai vs. DCIT CC 3(1), Mumbai

In the result, the appeal filed by the assessee is partly allowed for statistical purposes

ITA 2002/MUM/2017[2012-13]Status: DisposedITAT Mumbai31 Oct 2018AY 2012-13

Bench: Shri Saktijit Dey & Shri Manoj Kumar Aggarwalm/S. Vijay Grihniramn P. Ltd. Dcit. Central Circle-3(1) 201, Marine Chambers Mumbai Vs. 43, New Marine Lines Mumbai 400020 Pan – Aaacv2806N Appellant Respondent

For Appellant: Shri Mani Jain &For Respondent: Shri Rajeev Gubgotra
Section 23

…le Supreme Court in the case of Raj Dadarkar Associates vs. ACIT (2017) 394 ITR 592, after taking note of its own decisions in the case of Chennai Properties & Investments Ltd. vs. CIT (2015) 373 ITR 672 as well as Rayala Corporation Pvt. Ltd. vs. ACIT (2016) 386 ITR 500 has also upheld the assessment of income derived from letting out of properties under the head “income from house property”. In our considered view, the aforesaid decisions of the Hon'ble Supreme Court and Hon'ble Jurisdictional High Court need to be examined while considering the claim of the assessee that the unsold flats having shown as invent…

DCIT - 4(2)(2), Mumbai vs. Genuine Commercial Services Pvt. Ltd., Mumbai

ITA 5915/MUM/2016[2012-13]Status: DisposedITAT Mumbai24 Oct 2018AY 2012-13

Bench: Shri B.R. Baskaran (Am) & Shri Ramlal Negi (Jm)

Section 131(1)

…al has taken support of the decision rendered by Hon’ble Supreme Court in the case of Chennai Properties & Investment Ltd (373 ITR 673). The Ld A.R also placed reliance on the decision rendered by Hon’ble Supreme court in the case of Rayala Corporation P Ltd (386 ITR 500), wherein also identical view has been expressed. 11. In the above cited cases, the respective assessees were owner of certain properties and have derived rental income therefrom. The AO assessed the same under the head Income from House property. Considering the objective of the assessee, its intention and the manner of conducting its activitie…