https://www.taxtmi.com/caselaws?id=7471 Tax is chargeable only on real income, not on a notional gross amount, and a genuine overriding obligation can divert profits at source before they accrue to the nominal recipient. Applying that principle, the arrangement dated 15 August 1951 was held to be binding and to require division of the profits before they reached the assessee as his own income. Accordingly, only one-third of the share income was includible in the assessee's assessment, and the balance was not taxable in his hands. en-us Fri, 13 Dec 1968 00:00:00 +0530 Fri, 20 Feb 2009 12:58:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=7471 Tax is chargeable only on real income, not on a notional gross amount, and a genuine overriding obligation can divert profits at source before they accrue to the nominal recipient. Applying that principle, the arrangement dated 15 August 1951 was held to be binding and to require division of the profits before they reached the assessee as his own income. Accordingly, only one-third of the share income was includible in the assessee's assessment, and the balance was not taxable in his hands. Case-Laws Income Tax Fri, 13 Dec 1968 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=7471