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Relinquishment

Relinquishment, a relinquishment takes place when the owner withdraws himself from the property and abandons his rights thereto, CIT v. Rasiklal Maneklal, AIR 1989 SC 1333: (1989) 2 SCC 454: (1989) 2 SCR 179. (Income Tax Act, 1961, … Act, 1961, s. 45) Relinquishment, forsaking, or giving up. The abandonment of a right or thing, Black's Law Dictionary, 7th Edn., p. 1294. Means a release of a claim or portion of it. The essential features of

Machinery

with the object in each case of effecting so definite and specific a result (AIR 1922 PC 27), CIT v. Mir Mohd. Ali, AIR 1964 SC 1693 (1696): (1964) 7 SCR 846. [Income Tax Act, 1922, ss. 10(2) … Machinery. As to the riotous destruction of machinery, see Malicious Damage Act, 1861 (24 & 25 Vict. c. 97), s. 11, as amended. As … Manufacturing Company Ltd., AIR 1983 MP 161 (166). [M.P. Nagriya Statewar Sampati Kar Adhiniyam, (14 of 1964), s. 5(ii)] The air cooling plant is also

Profit bonus

have already been made. It is more like sharing of profits on the basis of a certain formula, CIT v. Swadeshi Cotton and Flour Mills (P) Ltd., AIR 1964 SC 1766 (1769). [Income-tax Act, 1961, s. 36(i)(ii)]

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Statutory percentage

its business. The dividends and taxes have also to be 'similarly apportioned', for the purposes of sub-s. (1), CIT v. T.V. Sundaram Iyenger and Sons (P) Ltd., AIR 1976 SC 25: (1976) 1 SCC 77: (1975) Supp SCR … profits were respectively the total income of the company in relation to each segment of its business. The dividends and taxes have also to be 'similarly apportioned', for the purposes of sub-s. (1), CIT v. T.V. Sundaram

Similarly apportioned

words 'similarly apportioned' convey a definite meaning and are not ambiguous. 'Similarly apportioned' means simply 'similarly split up', CIT v. T.V. Sundaram Iyenger and Sons (P) Ltd., AIR 1976 SC 255 (260): (1976) 1 SCC 77: (1975) Supp … company's business'. Thus, the explanation first refers to an apportionment or splitting up and then provides that the dividends and taxes shall be similarly apportioned, that is to say, similarly split up. Accordingly, the words 'similarly apportioned'

Premium and rent

but it helps the Court, having regard to the other circumstances, to ascertain the intention of the parties, CIT v. Panbori Tea Co. Ltd., AIR 1965 SC 1871 (1873): (1965) 3 SCR 811. [T.P. Act, 1882, s. 105] … clever phraseology. In some cases, the so-called premium is in fact advance rent and in others rent is deferred price. It is not the form but the substance of the transaction that matters. The nomenclature used may

Borne by the owner

owner is liable to discharge and not the actual sum paid by him in discharge of that liability, CIT v. Dalhousie Properties Ltd., (1984) 4 SCC 388: AIR 1987 SC 1867 (1868): (1985) 1 SCR 613. [Income Tax … Borne by the owner, the amount of tax which the owner is liable to discharge as stated in the proviso to s. 23(1) of the Act, i.e., the liability to pay tax imposed

Not in order

be something in the application. It can also be one in the procedure prescribed for making the application, CIT v. Ashoka Engineering Co., 1993 Supp (1) SCC 754: AIR 1993 SC 858 (860). [Income Tax Act, 1961 s. … Not in order, the defect need not be something in the application. It can also be one in the procedure prescribed for making

Reassess

of any of the grounds contemplated by the provisions of s. 147(b) read with the Ex-planation (1) thereto, CIT v. Sun Engineering, AIR 1993 SC 43 (50): (1992) 4 SCC 363. (Income Tax Act, 1961, s. 147)

Net profits

profits and are to be ascertained after deduction of excess profits tax which is payable by the assessee, CIT v. Delhi Flour Mills Co. Ltd., AIR 1959 SC 185 (188): 1959 Supp (1) SCR 28. [Excess Profits Tax … Net profits, clear profits after all deductions, see Watson v. Haggitt, 1928 AC 127. [s. 42, Indian Trusts Act] Net profits, the 'net profits' means

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