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Consideration received for assigning rights, claims and...
Capital character of assignment consideration prevents taxation as residuary income, while unsupported interest-related expenditure remains non-deductible.
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Consideration received for assigning rights, claims and entitlements connected with disputed partnership property and litigation is capital in character where it represents either an enforceable beneficial or proprietary interest or merely a litigative right or right to sue. Complete divestment of the underlying source does not become revenue income merely because capital gains tax may not apply; the residuary income head applies only to receipts that are first income. The addition as income from other sources was therefore deleted. Expenditure claimed against interest income remains deductible only when proved to have been incurred wholly and exclusively to earn that income. As no direct and proximate nexus was established, the disallowance was sustained.
Consideration received for assigning rights, claims and entitlements connected with disputed partnership property and litigation is capital in character where it represents either an enforceable beneficial or proprietary interest or merely a litigative right or right to sue. Complete divestment of the underlying source does not become revenue income merely because capital gains tax may not apply; the residuary income head applies only to receipts that are first income. The addition as income from other sources was therefore deleted. Expenditure claimed against interest income remains deductible only when proved to have been incurred wholly and exclusively to earn that income. As no direct and proximate nexus was established, the disallowance was sustained.
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