https://www.taxtmi.com/caselaws?id=5640 SC upheld the HC's judgment, dismissing the Revenue's appeal and affirming that the Tribunal was not justified in treating the sum as the assessee's income for AY 1960-61. The Court agreed the HC properly analyzed facts and mixed questions of law and fact, finding the transaction to be a loan rather than commission or business receipt. The circumstances cited by Revenue (no security, non-repayment, no interest, contemporaneous commercial agreements) did not suffice to convert the sum into income. Appeal dismissed; no costs. en-us Wed, 18 Feb 1998 00:00:00 +0530 Fri, 10 Oct 2025 17:13:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=5640 SC upheld the HC's judgment, dismissing the Revenue's appeal and affirming that the Tribunal was not justified in treating the sum as the assessee's income for AY 1960-61. The Court agreed the HC properly analyzed facts and mixed questions of law and fact, finding the transaction to be a loan rather than commission or business receipt. The circumstances cited by Revenue (no security, non-repayment, no interest, contemporaneous commercial agreements) did not suffice to convert the sum into income. Appeal dismissed; no costs. Case-Laws Income Tax Wed, 18 Feb 1998 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=5640