Earned income under section 2(6AA)(c) extends to periodic payments linked to past services, not just pension allowances.

Section 2(6AA)(c) was construed to include within earned income not only pension or superannuation allowance, but also other periodic allowances paid in respect of past services. The High Court held that the phrase "other allowances" was not confined by ejusdem generis to pension or superannuation allowance alone, and could extend to a commission traced to the past services of the assessee's deceased father under the assigned agreement. On that basis, the amount received was correctly treated as earned income and the reference was answered against the Revenue.

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Issues: Whether commission received by the assessee under the assigned agreement was liable to be treated as earned income under section 2(6AA)(c).

Analysis: The provision defined earned income to include income chargeable under the head "Other sources" where it represented pension, superannuation or other allowance given in respect of past services of the assessee or of a deceased person. The expression "other allowances" was held not to be confined by ejusdem generis to pension or superannuation allowance alone. A periodic payment made in respect of the past services of a deceased person could also fall within the expression "allowance", and the commission in question was traced to services rendered by the assessee's father under the agreement.

Conclusion: The amount received by the assessee was rightly treated as earned income and the reference was answered against the Revenue.

Ratio Decidendi: Under section 2(6AA)(c), "other allowances" includes periodical payments made in respect of the past services of a deceased person and is not confined to pension or superannuation allowance.

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