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    <title>1972 (1) TMI 30 - KERALA High Court</title>
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    <description>Contractual payments to a State Government were treated as a diversion of profits by title paramount where the agreement created a charge on net profits before they reached the assessee in the commercial sense. Applying the distinction between income diverted at source and income merely applied after receipt, the specified amounts were held not to form part of taxable income. The same payments were also characterised as revenue expenditure incurred under the contractual arrangement and were therefore deductible in computing business income under the applicable income-tax provisions.</description>
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      <description>Contractual payments to a State Government were treated as a diversion of profits by title paramount where the agreement created a charge on net profits before they reached the assessee in the commercial sense. Applying the distinction between income diverted at source and income merely applied after receipt, the specified amounts were held not to form part of taxable income. The same payments were also characterised as revenue expenditure incurred under the contractual arrangement and were therefore deductible in computing business income under the applicable income-tax provisions.</description>
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