Exemption of partner's share: partners are not taxable on firm income including amounts exempted or deducted at firm level. The firm's total income for the non-attribution rule includes amounts exempt or deductible under the tax law; once the firm is assessed and taxed on that income, the profit credited to partners cannot be taxed again in their hands, and partners' credited profits remain exempt even if the firm's taxable income becomes nil due to exemptions or deductions.
Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
Provisions expressly mentioned in the judgment/order text.
Exemption of partner's share: partners are not taxable on firm income including amounts exempted or deducted at firm level.
The firm's total income for the non-attribution rule includes amounts exempt or deductible under the tax law; once the firm is assessed and taxed on that income, the profit credited to partners cannot be taxed again in their hands, and partners' credited profits remain exempt even if the firm's taxable income becomes nil due to exemptions or deductions.
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