https://www.taxtmi.com/caselaws?id=7201 Receipts from requisitioned vessels were treated as income from the assessee's existing transport business and fell within item 5(g) of the India-Pakistan double taxation Schedule, not the residuary item 9. The Court held that requisition and payment described as hire did not create a new and distinct source of income where the essential character of the business remained transport by vessels; only the user of the commercial asset and the identity of the customer changed. Accordingly, the first issue was answered in favour of the assessee and the residuary provision did not apply. en-us Wed, 03 May 1967 00:00:00 +0530 Thu, 12 Feb 2009 16:29:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=7201 Receipts from requisitioned vessels were treated as income from the assessee's existing transport business and fell within item 5(g) of the India-Pakistan double taxation Schedule, not the residuary item 9. The Court held that requisition and payment described as hire did not create a new and distinct source of income where the essential character of the business remained transport by vessels; only the user of the commercial asset and the identity of the customer changed. Accordingly, the first issue was answered in favour of the assessee and the residuary provision did not apply. Case-Laws Income Tax Wed, 03 May 1967 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=7201