https://www.taxtmi.com/caselaws?id=169595 Under a territorial income-tax charging provision, the real and practical source of a receipt must be identified from the transaction as a whole. A sum realised by a liquidator on the sale of mining claims was held not to be shown as a capital receipt, because the claims had been acquired and developed as part of a profit-making scheme and the liquidation sale was the culmination of that scheme rather than a mere capital realisation. The source of the receipt was also within Southern Rhodesia, since the company's business activity and the property that generated the money were situated in the territory. The appeal therefore failed on both the capital-receipt and territorial-source issues. en-us Thu, 25 Apr 1940 00:00:00 +0530 Mon, 27 Apr 2015 14:54:56 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=169595 Under a territorial income-tax charging provision, the real and practical source of a receipt must be identified from the transaction as a whole. A sum realised by a liquidator on the sale of mining claims was held not to be shown as a capital receipt, because the claims had been acquired and developed as part of a profit-making scheme and the liquidation sale was the culmination of that scheme rather than a mere capital realisation. The source of the receipt was also within Southern Rhodesia, since the company's business activity and the property that generated the money were situated in the territory. The appeal therefore failed on both the capital-receipt and territorial-source issues. Case-Laws Income Tax Thu, 25 Apr 1940 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=169595