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    <title>Stipend of articled clerk of CA is not taxable as income. In view of author, stipend is ‘capital receipt’ and is scholarship for education.</title>
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    <description>Stipends to articled clerks are regarded as capital receipts and scholarships rather than taxable income because they are paid to meet education and training costs (books, fees, coaching, living expenses) and form part of capital investment in human resources; substance over form controls and payments made to facilitate qualification-rather than as remuneration for services-are non taxable, as affirmed by tribunal reasoning distinguishing capital from revenue receipts.</description>
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      <title>Stipend of articled clerk of CA is not taxable as income. In view of author, stipend is ‘capital receipt’ and is scholarship for education.</title>
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      <description>Stipends to articled clerks are regarded as capital receipts and scholarships rather than taxable income because they are paid to meet education and training costs (books, fees, coaching, living expenses) and form part of capital investment in human resources; substance over form controls and payments made to facilitate qualification-rather than as remuneration for services-are non taxable, as affirmed by tribunal reasoning distinguishing capital from revenue receipts.</description>
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