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    <title>1985 (9) TMI 1 - Supreme Court</title>
    <link>https://www.taxtmi.com/caselaws?id=5902</link>
    <description>Earned income relief under section 2(6AA)(b) or section 2(6AA)(c) of the Indian Income-tax Act, 1922 was unavailable where beneficiaries received income under a wakf deed rather than as direct business profits earned by them. The Supreme Court noted that the receipt originated in the wakf instrument and was assessable under section 41(2), not as profits and gains of business carried on by the assessees in their own right. Clause (b) failed because the income did not arise directly from the assessees&#039; business activity, and clause (c) failed because there was no immediate nexus between personal exertion and the receipt. The claim for earned income relief was therefore rejected.</description>
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    <pubDate>Fri, 06 Sep 1985 00:00:00 +0530</pubDate>
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      <title>1985 (9) TMI 1 - Supreme Court</title>
      <link>https://www.taxtmi.com/caselaws?id=5902</link>
      <description>Earned income relief under section 2(6AA)(b) or section 2(6AA)(c) of the Indian Income-tax Act, 1922 was unavailable where beneficiaries received income under a wakf deed rather than as direct business profits earned by them. The Supreme Court noted that the receipt originated in the wakf instrument and was assessable under section 41(2), not as profits and gains of business carried on by the assessees in their own right. Clause (b) failed because the income did not arise directly from the assessees&#039; business activity, and clause (c) failed because there was no immediate nexus between personal exertion and the receipt. The claim for earned income relief was therefore rejected.</description>
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      <pubDate>Fri, 06 Sep 1985 00:00:00 +0530</pubDate>
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