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    <title>1966 (11) TMI 9 - ALLAHABAD High Court</title>
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    <description>Whether the assessee&#039;s entire receipt from a constituent firm or only his divisible share was taxable was resolved by treating the assessee&#039;s capital in the Bareilly firm as held in representation of original partners and governed by a contemporaneous reciprocal profit and loss sharing agreement. The Court applied the principle that where a partner holds an interest as representative of another and there exists an enforceable obligation to share profits and losses, receipts reflect divided entitlement rather than a post earning diversion; accordingly only one third of the Bareilly firm income was includible in the assessee&#039;s assessment and the balance was attributable to other partners under the sub partnership arrangement.</description>
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    <pubDate>Tue, 29 Nov 1966 00:00:00 +0530</pubDate>
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      <title>1966 (11) TMI 9 - ALLAHABAD High Court</title>
      <link>https://www.taxtmi.com/caselaws?id=6919</link>
      <description>Whether the assessee&#039;s entire receipt from a constituent firm or only his divisible share was taxable was resolved by treating the assessee&#039;s capital in the Bareilly firm as held in representation of original partners and governed by a contemporaneous reciprocal profit and loss sharing agreement. The Court applied the principle that where a partner holds an interest as representative of another and there exists an enforceable obligation to share profits and losses, receipts reflect divided entitlement rather than a post earning diversion; accordingly only one third of the Bareilly firm income was includible in the assessee&#039;s assessment and the balance was attributable to other partners under the sub partnership arrangement.</description>
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      <pubDate>Tue, 29 Nov 1966 00:00:00 +0530</pubDate>
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