https://www.taxtmi.com/caselaws?id=191745 A receipt assessed as income from undisclosed sources cannot be recharacterised as business income for excess profits tax unless the record contains material supporting that specific connection. The assessment material here did not state any reason showing that the sum arose from business activity, and the appellate material likewise only showed income from an undisclosed source. In the absence of a factual basis linking the receipt to business operations, the inference of business income was unwarranted and unsustainable. Prior treatment of a similar amount in the earlier year also indicated that it had not been treated as excess profits tax business income. en-us Wed, 20 Mar 1957 00:00:00 +0530 Mon, 17 Apr 2017 17:08:26 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=191745 A receipt assessed as income from undisclosed sources cannot be recharacterised as business income for excess profits tax unless the record contains material supporting that specific connection. The assessment material here did not state any reason showing that the sum arose from business activity, and the appellate material likewise only showed income from an undisclosed source. In the absence of a factual basis linking the receipt to business operations, the inference of business income was unwarranted and unsustainable. Prior treatment of a similar amount in the earlier year also indicated that it had not been treated as excess profits tax business income. Case-Laws Income Tax Wed, 20 Mar 1957 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=191745