Case of Sanand Properties Pvt Ltd vs Jt Commissioner of Income Tax, SC Judgement Dated 12th May 2026. The apex court held that contractual right to withdraw 35% of gross sale proceeds upfront, before meeting project expenses (borne from the remaining 65%), creates an overriding title and amounts to diversion of income at source. The 35% is therefore taxable as a business receipt and cannot be treated as a mere ‘profit share’ exempt under the AOP-member pass-through provisions.