https://www.taxtmi.com/caselaws?id=7851 Special remuneration was exempt under the 1928 notification only if all prescribed conditions were cumulatively satisfied, including that the payment was made out of, or determined with reference to, business profits and that the corresponding deduction had been disallowed on that basis. Because the payer-company's deduction was disallowed as not wholly and exclusively for business, and not because the payment was treated as profit-linked remuneration within the notification, the exemption condition was not met. The receipt of Rs. 60,000 was therefore assessable. en-us Wed, 25 Feb 1970 00:00:00 +0530 Mon, 23 Mar 2009 09:15:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=7851 Special remuneration was exempt under the 1928 notification only if all prescribed conditions were cumulatively satisfied, including that the payment was made out of, or determined with reference to, business profits and that the corresponding deduction had been disallowed on that basis. Because the payer-company's deduction was disallowed as not wholly and exclusively for business, and not because the payment was treated as profit-linked remuneration within the notification, the exemption condition was not met. The receipt of Rs. 60,000 was therefore assessable. Case-Laws Income Tax Wed, 25 Feb 1970 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=7851