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TMI Blog2015 (3) TMI 320X X X X Extracts X X X X X X X X Extracts X X X X ..... igh Court] and Chennai properties and Investments Ltd. (2003 (3) TMI 28 - MADRAS High Court) are distinguishable on facts. In those cases, the receipts itself are rental receipts. Whereas, in the present case, the assessee itself had retained the possession and there is no fiduciary relationship of landlord and tenant. The Tribunal, by going into the individual aspects of the business to correc ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... right in law in holding that Godown/Ware Houses rents received by the assessee as business income, even though the rental income received by the assessee in the nature of income from house property? 2. The brief facts of the case are as follows: The assessee is having godowns/warehouses. The Assessing Officer completed the assessment and held that the income from warehousing has to be taxe ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... l clearly held that the assessee company is providing logistic services, which are complex in nature, to its clients for the purpose of earning profit and hence it is a business activity. 4. For better understanding, we extract below the findings of the Tribunal: 18. On the surrounding set of facts and circumstances, it is well established beyond doubt that the assessee-company carried out ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Standing Counsel appearing for the Revenue and the learned counsel appearing for the assessee and perused the materials placed before this Court. 7. It is seen that the findings of fact arrived at by the Tribunal is not in dispute. The decision of the Supreme Court in the case of Commissioner of Income Tax V. Indian Warehousing Industries Ltd. reported in 258 ITR 93 and that of the jurisdiction ..... X X X X Extracts X X X X X X X X Extracts X X X X
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