https://www.taxtmi.com/caselaws?id=182401 A composite lump-sum received on release of contractual rights had to be apportioned where it covered both revenue and capital elements. The part referable to profits already earned for past services retained its revenue character and was taxable as such, while the components relating to surrender of royalty rights and a right of pre-emption were capital in nature. The taxing authority could not treat the whole receipt as revenue merely because one component was taxable. The receipt was therefore a mixed one, requiring reasonable allocation between taxable revenue and non-taxable capital elements. en-us Fri, 06 May 1955 00:00:00 +0530 Mon, 09 May 2016 18:02:29 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=182401 A composite lump-sum received on release of contractual rights had to be apportioned where it covered both revenue and capital elements. The part referable to profits already earned for past services retained its revenue character and was taxable as such, while the components relating to surrender of royalty rights and a right of pre-emption were capital in nature. The taxing authority could not treat the whole receipt as revenue merely because one component was taxable. The receipt was therefore a mixed one, requiring reasonable allocation between taxable revenue and non-taxable capital elements. Case-Laws Income Tax Fri, 06 May 1955 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=182401