2022 (10) TMI 616 - SC - Income Tax

Owner of the plant for the purpose of section 32 - Income generated through lease - Scope of terms own ownership and owned Revenue receipt/income accrued - HELD THAT - On construing the relevant clauses it is apparent that the respondent-assessee had become the owner of the plant and machinery. Further the lease rentals in entirety have been taxed as a revenue receipt/income accrued and taxable. In view of the aforesaid factual background we do not find any good ground and reason to interfere with the final conclusion and decision of the High Court. Accordingly the appeal is dismissed.

Summary

The Supreme Court dismissed the appeal as the respondent-assessee was deemed the owner of the plant and machinery, and lease rentals were taxed as revenue receipt. No interference with the High Court's decision was found.