9911796707
TMI Blog2019 (2) TMI 1610X X X X Extracts X X X X X X X X Extracts X X X X ..... was completed under Section 143(3) of the Income Tax Act. So also, for the assessment year 2003-04 and assessment year 2005-06, the assessment was completed under Section 143(3). The claim of the assessee of the said income being a business income was accepted. The assessee is not receiving any rent amount but is receiving 1% of the total revenue earned by KHIL and does not get any fix amount ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 2. Whether on the facts and in the circumstances of the case and in law, the ITAT was justified in treating the receipts for the lease of its hotel as business income ignoring the finding given by the CIT (A) that the transaction between the assessee and KHIL were not at arms length and therefore, for the purpose of determining the fair market value, the provisions of Section 23(1)(a) of ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... he Income Tax Act. The claim of the assessee of the said income being a business income was accepted. 8. The assessee is not receiving any rent amount but is receiving 1% of the total revenue earned by KHIL and does not get any fix amount as rent. These aspects are considered by the Tribunal. 9. Question No.2 being dependent upon Question No.1, no substantial question of law ar ..... X X X X Extracts X X X X X X X X Extracts X X X X
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