https://www.taxtmi.com/caselaws?id=7262 Interim payments received under section 50 of the Madras Estates Abolition Act, 1948 were treated as revenue receipts, not capital compensation, and were therefore taxable under the Income-tax Act. The assessing officer's quasi-judicial function was held to depend on the statute, so a CBDT letter or prior departmental treatment could not bind the officer or create an enforceable article 14 claim. As no lack of jurisdiction was shown in the reopening notices, writ relief by prohibition was unavailable; mandamus also failed because there was no legal duty to assess contrary to the Act or the officer's independent judgment. en-us Tue, 22 Aug 1967 00:00:00 +0530 Mon, 16 Feb 2009 12:13:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=7262 Interim payments received under section 50 of the Madras Estates Abolition Act, 1948 were treated as revenue receipts, not capital compensation, and were therefore taxable under the Income-tax Act. The assessing officer's quasi-judicial function was held to depend on the statute, so a CBDT letter or prior departmental treatment could not bind the officer or create an enforceable article 14 claim. As no lack of jurisdiction was shown in the reopening notices, writ relief by prohibition was unavailable; mandamus also failed because there was no legal duty to assess contrary to the Act or the officer's independent judgment. Case-Laws Income Tax Tue, 22 Aug 1967 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=7262