https://www.taxtmi.com/caselaws?id=69562 For income-tax purposes, the true legal and commercial character of a transaction governs its tax treatment. A security deposit received under a so-called licence deed was held to be part of the integrated sale consideration for the flats and related rights, so it was taxable as a trading receipt. Interest paid on a deposit from Southern Investments was treated as a business-related outlay rather than capital cost, so it was allowable as a revenue deduction. For section 80HHC, the assessee was treated as the real exporter because the contracts, shipping papers, bank arrangements and registration stood in its name, with Kaveri Sea Foods acting only as agent; the export deduction and related expenses were allowed. en-us Fri, 13 Dec 1991 00:00:00 +0530 Thu, 07 Apr 2011 16:28:33 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=69562 For income-tax purposes, the true legal and commercial character of a transaction governs its tax treatment. A security deposit received under a so-called licence deed was held to be part of the integrated sale consideration for the flats and related rights, so it was taxable as a trading receipt. Interest paid on a deposit from Southern Investments was treated as a business-related outlay rather than capital cost, so it was allowable as a revenue deduction. For section 80HHC, the assessee was treated as the real exporter because the contracts, shipping papers, bank arrangements and registration stood in its name, with Kaveri Sea Foods acting only as agent; the export deduction and related expenses were allowed. Case-Laws Income Tax Fri, 13 Dec 1991 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=69562