TMI Blog1987 (11) TMI 16X X X X Extracts X X X X X X X X Extracts X X X X ..... for our opinion under section 256(1) of the Income-tax Act, 1961, viz. : "1. Whether, on the facts and in the circumstances of the case, the Income-tax Appellate Tribunal was justified in holding that the income derived from the letting out of sheds owned by the assessee should be assessed as income from business ? 2. Whether, on the facts and in the circumstances of the case, the Income-tax ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... and start their business there. In some cases, plots or sheds put up by the Corporation are sold and in some cases, they are given out on hire basis and in yet some other cases, they are leased out. The assessee is also given subsidy by the State Government. In the course of its activities, it receives and disburses funds and it normally keeps its funds in a bank. Here, we are concerned only with ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Scale Industrial Development Corporation [1989] 175 ITR 352 (AP) R. C. No. 287 of 1980, dated March 5, 1987). Indeed, in the present case, the Tribunal has followed its own earlier judgment relating to the other corporation and held in favour of the assessee herein. Following the said decision, we answer the first question referred in the affirmative, that is, in favour of the assessee and against ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ial Corporation Ltd. v. CIT [1984] 150 ITR 533. There, the assessee, the Andhra Pradesh State Financial Corporation, which was engaged in lending moneys to industries in the interest of industrial progress, kept some of its surplus funds in the form of Andhra Pradesh State Development Loan, which could be easily converted into cash as and when the assessee required funds for carrying on its busine ..... X X X X Extracts X X X X X X X X Extracts X X X X
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