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    <title>1945 (12) TMI 1 - ALLAHABAD HIGH COURT</title>
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    <description>Section 4(2) of the Income-tax Act, 1922 created a deeming fiction under which remittances received in British India by a resident wife from a non-resident husband were treated as income accruing in British India, so the Kalsia allowances were assessable in her hands. Repeated payments from Nabha State were not shown to be the wife&#039;s personal income and did not fall within that deeming rule, so they were not assessable as such under the Act. The claim to immunity under the canons of international law was rejected because no legal basis extended the ruler&#039;s immunity to the wife in respect of income accruing, arising or received in British India.</description>
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    <pubDate>Fri, 21 Dec 1945 00:00:00 +0530</pubDate>
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      <title>1945 (12) TMI 1 - ALLAHABAD HIGH COURT</title>
      <link>https://www.taxtmi.com/caselaws?id=175835</link>
      <description>Section 4(2) of the Income-tax Act, 1922 created a deeming fiction under which remittances received in British India by a resident wife from a non-resident husband were treated as income accruing in British India, so the Kalsia allowances were assessable in her hands. Repeated payments from Nabha State were not shown to be the wife&#039;s personal income and did not fall within that deeming rule, so they were not assessable as such under the Act. The claim to immunity under the canons of international law was rejected because no legal basis extended the ruler&#039;s immunity to the wife in respect of income accruing, arising or received in British India.</description>
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      <pubDate>Fri, 21 Dec 1945 00:00:00 +0530</pubDate>
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