COMMISSIONER OF INCOME TAX Vs. SHANMUGHAM V

JUDGEMENT

(1.) THE following question has been referred in pursuance of the directions of this court :

(2.) THE assessee was carrying on business in groceries. He constructed a building between November, 1965, and September, 1967. THE building consisted of 68 rooms, some of which had attached bath-rooms. THE rooms were separately furnished and let out for varying durations. He employed a manager, a supervisor, scavengers, room boys and watchmen for the purpose of looking after the building and its amenities. He provided also the facility of telephone, electricity and water supply at his expense. He realised Rs. 15,545 and Rs. 39,331 as gross income from the tenants by, letting out the rooms in this property, which was known as "Vinayaka Lodge".