https://www.taxtmi.com/caselaws?id=152254 Compensation paid solely for loss of employment was treated as falling within the exception in Explanation 2 to section 7(1) of the Indian Income-tax Act, 1922, and not as profits in lieu of salary. The controlling test was the real character and purpose of the receipt, not whether the compensation was legally recoverable as an enforceable claim. The Tribunal's finding that shares were allotted only as compensation for termination was accepted, and the fact that the assessee later obtained similar employment did not alter the tax character of the payment. The dissent required a legally enforceable entitlement and would have taxed the receipt as salary-related profits. en-us Wed, 12 Dec 1962 00:00:00 +0530 Thu, 08 May 2014 16:55:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=152254 Compensation paid solely for loss of employment was treated as falling within the exception in Explanation 2 to section 7(1) of the Indian Income-tax Act, 1922, and not as profits in lieu of salary. The controlling test was the real character and purpose of the receipt, not whether the compensation was legally recoverable as an enforceable claim. The Tribunal's finding that shares were allotted only as compensation for termination was accepted, and the fact that the assessee later obtained similar employment did not alter the tax character of the payment. The dissent required a legally enforceable entitlement and would have taxed the receipt as salary-related profits. Case-Laws Income Tax Wed, 12 Dec 1962 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=152254