Sec. 28(i) of the Income-tax Act, 1961 – Business income – Revenue filed Tax Appeal before High Court against the order of ITAT in holding that the income derived from letting out of property to the tenants for the purpose of running a software technology park as 'income from business' in the hands of the owner of the property and; the income from letting out of building comprising separate modules with uplinking facility with VSNL as income from business assessable under Section 28 of the Act. High Court rejected the appeal of the revenue holding that “when the company had taken lands on 90 years lease with the objects of constructing I.T. Company with all its infrastructural facilities, the same was for the purpose of establishing and providing the amenities required to run, maintain, manage or administer computer centres for manufacturing or processing software packages and/or hardware materials and components required for computer industry, to exploit it as a business proposition. Thus, the lease rentals are assessable as business income only. Revenue withdrew its SLP in Supreme Court – CIT Vs. ELNET TECHNOLOGIES LTD. [2020] 271 TAXMAN 025 (SC)