of this Court in East India Housing and Land Development Trust Ltd. v. CIT [(1961) 42 ITR 49] support the contention of the Revenue. There, a company, which was incorporated with the objects of buying and developing landed properties and promoting and developing markets, purchased 10 bighas of land in the town of Calcutta and set up a market therein. The question was whether the income realised from the tenants of the shops and stalls was liable to be taxed as “business income” under Section 10 of the Income Tax Act or as income from property under Section 9 thereof. This Court held that the said income fell under the specific head mentioned in Section 9 of the Act. This case also does not lay down that the income from the shops is not the income in the business. In CIT v. Express Newspapers Ltd [(1964) 53 ITR 250, 260] this Court held that both Section 26(2) and the proviso thereto dealt only with profits and gains of a business, profession, or vocation and they did not provide for