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    <title>1948 (9) TMI 11 - BOMBAY HIGH COURT</title>
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    <description>Income exempted under section 25(4) of the Indian Income-tax Act, 1922 was treated as excluded from total income for rate computation because the Act used an express inclusion mechanism in section 16 where exempt income was intended to be brought in for that purpose. The analysis distinguished between income exempt from tax and income excluded from total income, and applied that statutory structure to reject rate-based inclusion of the exempt partnership share. On super-tax, the proviso to section 25(4) was noted as preserving liability where prior assessment conditions were not met, and the amount received on dissolution was treated as the assessable figure on the facts discussed.</description>
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    <pubDate>Wed, 22 Sep 1948 00:00:00 +0530</pubDate>
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      <title>1948 (9) TMI 11 - BOMBAY HIGH COURT</title>
      <link>https://www.taxtmi.com/caselaws?id=183700</link>
      <description>Income exempted under section 25(4) of the Indian Income-tax Act, 1922 was treated as excluded from total income for rate computation because the Act used an express inclusion mechanism in section 16 where exempt income was intended to be brought in for that purpose. The analysis distinguished between income exempt from tax and income excluded from total income, and applied that statutory structure to reject rate-based inclusion of the exempt partnership share. On super-tax, the proviso to section 25(4) was noted as preserving liability where prior assessment conditions were not met, and the amount received on dissolution was treated as the assessable figure on the facts discussed.</description>
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      <pubDate>Wed, 22 Sep 1948 00:00:00 +0530</pubDate>
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