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    <title>1952 (8) TMI 24 - ALLAHABAD HIGH COURT</title>
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    <description>Profits from a profession are excluded from excess profits tax where they depend wholly or mainly on the personal qualifications of the persons carrying it on. On the facts, the Tribunal could not rely on a broad generalisation that auctioneering in India required no special qualification; it had to assess the particular circumstances, including the firm&#039;s experience, the partners&#039; skill and efficiency, the attraction of government work, and the firm&#039;s comparative success. The court held that auctioneering itself involved skill, experience and judgment in obtaining business and sales, so the assessee&#039;s income depended mainly on the partners&#039; personal qualifications and the issue was answered in its favour.</description>
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    <pubDate>Tue, 26 Aug 1952 00:00:00 +0530</pubDate>
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      <title>1952 (8) TMI 24 - ALLAHABAD HIGH COURT</title>
      <link>https://www.taxtmi.com/caselaws?id=192447</link>
      <description>Profits from a profession are excluded from excess profits tax where they depend wholly or mainly on the personal qualifications of the persons carrying it on. On the facts, the Tribunal could not rely on a broad generalisation that auctioneering in India required no special qualification; it had to assess the particular circumstances, including the firm&#039;s experience, the partners&#039; skill and efficiency, the attraction of government work, and the firm&#039;s comparative success. The court held that auctioneering itself involved skill, experience and judgment in obtaining business and sales, so the assessee&#039;s income depended mainly on the partners&#039; personal qualifications and the issue was answered in its favour.</description>
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      <pubDate>Tue, 26 Aug 1952 00:00:00 +0530</pubDate>
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