C.I.T. II JODHPUR vs. M/S JEEWAN RAM CHOUDHARY
ITA/185/2013HC Rajasthan17 Sept 2019
Bench: SANGEET LODHA,VINIT KUMAR MATHUR
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