Sec. 22 & 28 of Income tax Act, 1961 – Income from House Property – The substantial question of law involved in the appeals filed by the Assessees is "Whether the income earned by the Assessees during the A.Yrs in question from letting out of its warehouses or property to lessees, is taxable under the head 'Income from Business' or 'Income from House Property?". The Tribunal against the Assessees held that such income to be taxable as 'Income from House Property', mainly relying upon the judgment of Division Bench in the case of CIT vs. Chennai Properties and Investment Pvt. Ltd. [(2004) 266 ITR 685], which came to be reversed by the Hon'ble Supreme Court later on. High Court while allowing the appeal answered the aforesaid question in the favour of assessee and held that:– in cases where the earning of the rental income is the exclusive or predominant business of the Assessee, the income earned by way of lease money or rentals by letting out of the property cannot be taxed under the Head 'Income from hosue property', but can only be taxed under the Head 'Income from business income – PSTS HEAVY LIFT & SHIFT LTD. Vs. DEPUTY CIT [2020] 422 ITR 497 (MAD)