COMMISSIONER OF INCOME-TAX, BOMBAY CITY-1, BOMBAY vs NATIONAL STORAGE PVT. LTD., BOMBAY

The Supreme Court ruled that the assessee, a company providing vaults for film storage, was to be assessed under Section 10 of the Indian Income-tax Act, 1922, rather than Section 9. The Court established that the income derived was from carrying on a business adventure rather than merely from property rights, as the agreements constituted licenses for services rather than leases. The Court held that the nature of the income was tied to the business activities conducted in the premises, affirming the Bombay High Court's decision.