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    <title>1971 (1) TMI 32 - ALLAHABAD High Court</title>
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    <description>Income received by a beneficiary under a wakf deed from business run under that deed was examined to determine whether it qualified as earned income under the Indian Income-tax Act, 1922. The majority reasoned that the character of the receipt depended on the title under which it was received, namely the wakf deed, and not merely on the business source; because the assessee was taxed as beneficiary and not as mutawalli, the share was neither income from business carried on by the assessee nor income immediately derived from personal exertion. It therefore did not qualify as earned income. H. N. Seth J dissented, treating the managing beneficiary and recipient as the same person for this purpose and accepting earned income relief.</description>
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    <pubDate>Tue, 19 Jan 1971 00:00:00 +0530</pubDate>
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      <title>1971 (1) TMI 32 - ALLAHABAD High Court</title>
      <link>https://www.taxtmi.com/caselaws?id=8168</link>
      <description>Income received by a beneficiary under a wakf deed from business run under that deed was examined to determine whether it qualified as earned income under the Indian Income-tax Act, 1922. The majority reasoned that the character of the receipt depended on the title under which it was received, namely the wakf deed, and not merely on the business source; because the assessee was taxed as beneficiary and not as mutawalli, the share was neither income from business carried on by the assessee nor income immediately derived from personal exertion. It therefore did not qualify as earned income. H. N. Seth J dissented, treating the managing beneficiary and recipient as the same person for this purpose and accepting earned income relief.</description>
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      <pubDate>Tue, 19 Jan 1971 00:00:00 +0530</pubDate>
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