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Showing contexts for: Customs Agent in Commissioner Of Income Tax vs Gwl Properties Ltd on 9 January, 2026Matching Fragments
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5. The assessee was engaged in the activity of manufacturing and trading, IATA approved cargo agent and customs house agent, and was not carrying on the business of purchase and sale of properties. Hence, it contested the re- assessment adopting the stand that any income earned from sale of property would be assessable only under the head ‘capital gains’ and would have no incidence of business activity.
6. I have carefully considered the facts of the case and the submissions of the Id.AR. It is seen that the appellant company is engaged in the business as IATA approved cargo agents, customs house agents and property development. Thus one of the main activities of the appellant company is property development. The transactions carried out by the appellant is to be examined in the background of the business the appellant is engaged in. The Assessing Officer treated the profit on sale of land as business income because the assessee company has been engaged in the business of development of property. During the year, it has sold land of 22.28 acres. The cost as per the books was only Rs.21,769/-