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    <title>1977 (3) TMI 1 - Supreme Court</title>
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    <description>Surcharge collected separately on admission tickets for local charities was treated as diverted at source, not as taxable income of the assessee. The levy was imposed under a resolution for a specific charitable purpose and was not part of the admission price; it was impressed with an obligation in the nature of trust for charitable application. Applying the test whether the amount ever reached the assessee as income, the receipt was held to be diverted before accrual. The distinction between diversion of income at source and application of income after receipt supported exclusion of the surcharge from taxable income.</description>
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      <title>1977 (3) TMI 1 - Supreme Court</title>
      <link>https://www.taxtmi.com/caselaws?id=6504</link>
      <description>Surcharge collected separately on admission tickets for local charities was treated as diverted at source, not as taxable income of the assessee. The levy was imposed under a resolution for a specific charitable purpose and was not part of the admission price; it was impressed with an obligation in the nature of trust for charitable application. Applying the test whether the amount ever reached the assessee as income, the receipt was held to be diverted before accrual. The distinction between diversion of income at source and application of income after receipt supported exclusion of the surcharge from taxable income.</description>
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