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2014 (2) TMI 174 - AT - Income TaxHeads of income - Income from house property OR business income - Held that:- The tribunal has given a definite and clear finding of the assessee providing, apart from built-up space, a range of services and facilities, which are intrinsically linked to the letting of the building, specifying the machinery deployed, so that it is a case of composite letting. Further, though the services stand provided per different agreements, they cannot be considered as de hors and separate from each other inasmuch as they form part of a single arrangement there was no reason for any change in the consistent view adopted by the tribunal Relying upon Sultan Brothers (P.) Ltd. vs. CIT [1963 (12) TMI 4 - SUPREME Court] - the assessment of the gross receipt as business income is directed. Re-computation of the disallowance u/s.14A of the Act Held that:- The decision in Godrej & Boyce Mfg. Co. Ltd. v. Dy. CIT [2010 (8) TMI 77 - BOMBAY HIGH COURT] followed - a statutory disallowance is warrented, which had to be made toward both direct and indirect expenditure, observing the assessee to have incurred administrative expenditure and financial charges - there is no cause for any grievance to either side - The A.O. has to be satisfied with the assessee's claim u/s.14A, and compute the disallowance in a reasonable manner both qua direct as well as indirect expenditure, giving his definite findings Decided partly in favour of Assessee.
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