“Section 132(14)”

Rental income from immovable property owned by an assessee must be assessed under the head 'Income from House Property' (Section 22), even if the assessee is engaged in the business of real estate or property development and leasing. This emphasizes the mandatory classification of income under its specific statutory head.

Surrender of tenancy rights is a transfer of a capital asset, and the consideration received is a capital receipt subject to capital gains tax. If the cost of acquisition cannot be determined, the transfer of such an asset was not taxable under capital gains prior to the amendment of Section 55(2) in 1995.

The heads of income specified in the Income Tax Act are mutually exclusive, requiring any item of income to be charged and computed solely under its specific statutory head, with Section 56 (Income from Other Sources) serving as a residuary provision.

This case establishes principles for determining the validity of a special audit direction issued under Section 142(2A) and its impact on the extended period of limitation under Section 153(3) Explanation 1(iii), often considered in the context of natural justice.

Whether an income falls under one head of income or another is to be decided according to the common notions of a practical man, as the Income-tax Act provides no specific guidance. The Income-tax Act provides no specific guidance for determining the appropriate head of income.

When a taxpayer's sole source of income is from the letting out of properties, such rental income is to be assessed under the head 'Income from House Property'.

A transaction is not chargeable to capital gains tax if the computation provisions under Section 48 of the Income-tax Act, 1961, cannot be applied to it, meaning it was never intended by Section 45 to be subject to the charge.

Under Section 68 of the Income-tax Act, the assessee's burden is limited to explaining the immediate source of a cash credit; there is no legal requirement to explain the source of the source.