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Microlesson · 5-min read

Charging Section & Conditions for Chargeability [Section 22]

## Income from House Property — Charging Section [Section 22]

### The charge

> The annual value of property consisting of buildings or land appurtenant thereto, owned by the assessee, is chargeable to tax under the head 'Income from House Property' — provided the property is not used by the owner for his own business/profession.

### Exceptions (taxed under PGBP, not House Property)

  • Business use: If the assessee uses the property (or part of it) for his own business/profession, that portion is excluded from Section 22.
  • Business of renting: If the assessee's primary business is letting out commercial properties, that income is charged under business income.

### The three conditions for chargeability

1. Property must be a building or land appurtenant thereto

  • Buildings: residential houses, factories, offices, shops, godowns, other commercial buildings.
  • Land appurtenant: gardens, parking garages, etc., connected with the building.
  • ⚠️ Income from letting out vacant land → taxed under Other Sources or PGBP.
  • ⚠️ Rent from an under-construction property → taxable under Income from Other Sources.

2. The assessee must be the owner

  • Registration of the sale deed is NOT mandatory for ownership.
  • Ownership includes freehold, leasehold, and deemed ownership u/s 27.
  • The owner of the building need not own the land beneath it.
  • Ownership must exist during the previous year (not necessarily the assessment year).
  • If ownership is disputed in court, the Income Tax Department decides chargeability until the court rules.
  • Unrealised rent / arrears u/s 25A are taxable irrespective of ownership status.

3. Property usage

  • Can be residential or commercial.
  • Exclusion: if the owner uses it for his own taxable business/profession, it is not under this head.

4. Property held as stock-in-trade

  • Even if the property is stock-in-trade (inventory for sale), its annual value is still charged under Income from House Property (subject to the specific relaxation period for unsold stock).

Worked example

### Example 1

Vacant land: An assessee lets out a vacant plot for ₹1,00,000 p.a. with no building. → Taxed under Income from Other Sources / PGBP, NOT house property (no building or appurtenant land to a building).

### Example 2

Building vs land ownership: A owns a building constructed on land owned by B. Rental income from the building is taxable in A's hands under house property — the owner of the building need not own the land.

### Example 3

Disputed ownership: Two parties litigate ownership of a let-out house. Until the court decides, the Income Tax Department determines who is chargeable, and the rent is taxed accordingly.

⚠️ Common exam mistakes

  • Taxing income from vacant land under house property — it is taxed under Other Sources/PGBP.
  • Believing registration of the sale deed is required to be treated as 'owner' — it is not.
  • Assuming stock-in-trade property escapes house-property tax — its annual value is still charged (subject to relaxation).
  • Confusing letting out commercial property as a business (PGBP) with ordinary letting (house property).
  • Treating rent from an under-construction property as house property income — it is Income from Other Sources.
Reference: Section 22 (read with Section 27 and Section 25A) — Income-tax Act, 1961
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