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    <title>1952 (9) TMI 23 - HIGH COURT OF ALLAHABAD</title>
    <link>https://www.taxtmi.com/caselaws?id=97189</link>
    <description>The appellate authority&#039;s power on an assessee&#039;s appeal was treated as wide enough to confirm, reduce, enhance or annul an assessment, subject to giving reasonable opportunity before enhancement, so its jurisdiction was not confined to the grounds raised by the assessee. The commentary also states that profits earned by promoters before incorporation, where they acted for the proposed company and the company later adopted their acts, could be assessed in the company&#039;s hands because beneficial entitlement, not merely legal title, governed taxability. The result is that appellate annulment power and taxation of pre-incorporation income were both recognised as operative principles.</description>
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    <pubDate>Wed, 03 Sep 1952 00:00:00 +0530</pubDate>
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      <title>1952 (9) TMI 23 - HIGH COURT OF ALLAHABAD</title>
      <link>https://www.taxtmi.com/caselaws?id=97189</link>
      <description>The appellate authority&#039;s power on an assessee&#039;s appeal was treated as wide enough to confirm, reduce, enhance or annul an assessment, subject to giving reasonable opportunity before enhancement, so its jurisdiction was not confined to the grounds raised by the assessee. The commentary also states that profits earned by promoters before incorporation, where they acted for the proposed company and the company later adopted their acts, could be assessed in the company&#039;s hands because beneficial entitlement, not merely legal title, governed taxability. The result is that appellate annulment power and taxation of pre-incorporation income were both recognised as operative principles.</description>
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      <pubDate>Wed, 03 Sep 1952 00:00:00 +0530</pubDate>
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