Supreme Court upheld validity of reopening assessments for AY 2007‑08 and 2008‑09 for Sanand Properties, setting aside High Court’s quash order.
Court held income from AOP under Clause 7 is a 35% share of gross receipts, i.e., taxable revenue, not profit share.
Accordingly, Civil Appeal 744 2013 allowed, Civil Appeal 9107 2012 dismissed, and Civil Appeal 19487 2017 allowed, taxing SPPL’s share for AY 2008‑09 & 2009‑10.