Characterization of income - income arising from sub-licensing ...

December 19, 2023

Case Laws     Income Tax     HC

Characterization of income - income arising from sub-licensing of shops and establishment along with the various services - ITAT, after referring to section 27 (iiib) of the Income Tax Act defining the term “deemed owner” and Section 269UA(f) of the Act defining the word “transfer”; held that the income derived by the assessee is “Income from House Property.” - the ITAT has committed a manifest error of law to ignore the object and business activity of the appellant assessee company, and misunderstood the nature of transaction of sub-license. - HC

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