In Brief
The appellant filed an income tax return showing Rs. 67,200 for assessment year 1998-99. He had leased his property to family members at nominal rates; they sub-leased it at much higher rentals. The tax authorities reassessed his income at Rs. 6,38,400 based on the actual sub-lease rentals. The appellant challenged this through ITAT and the High Court, which upheld the assessment. The Supreme Court held that findings of fact regarding the bogus lease structure and the appellant's true beneficial ownership of the income cannot be interfered with. However, it noted that the same income was wrongly taxed also at the hands of his wife, son, and daughter-in-law, allowing them to seek separate redressal.
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