PTL ENTERPRISES LTD. vs. THE DEPUTY COMMISSIONER OF INCOME TAX
ITA/227/2013HC Kerala22 Jul 2021
Bench: HONOURABLE MR.JUSTICE S.V.BHATTI,HONOURABLE MR. JUSTICE BECHU KURIAN THOMAS
For Appellant: THE DEPUTY COMMISSIONER OF INCOME TAXFor Respondent: M/S.PTL ENTERPRISES LTD
2(14) is not a word of art but
a word of commercial implication. The bottom line is the availability
of assets, activities carried out for exploiting the assets and that the
assessee is not a mere onlooker in the activities of the company or a
passive recipient of rent for utilization of facilities.
18. Applying the above ratio
