https://www.taxtmi.com/caselaws?id=193344 A contractual subsidy paid under railway agreements was treated as taxable income because, on receipt, it became part of the companies' funds and was available like earnings, even though the contract directed its ultimate application for shareholders. The guaranteed interest payable to shareholders was not deductible under Section 10(2)(iii) of the Indian Income-tax Act, 1922, and the companies' independent trading profits remained taxable. The commentary applies the principle that a payment received under a guarantee arrangement may still be income in the company's hands where it forms part of its coffers, and that contractual hardship does not alter the statutory incidence of tax. en-us Tue, 02 Apr 1935 00:00:00 +0530 Tue, 25 Jul 2017 11:37:33 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=193344 A contractual subsidy paid under railway agreements was treated as taxable income because, on receipt, it became part of the companies' funds and was available like earnings, even though the contract directed its ultimate application for shareholders. The guaranteed interest payable to shareholders was not deductible under Section 10(2)(iii) of the Indian Income-tax Act, 1922, and the companies' independent trading profits remained taxable. The commentary applies the principle that a payment received under a guarantee arrangement may still be income in the company's hands where it forms part of its coffers, and that contractual hardship does not alter the statutory incidence of tax. Case-Laws Indian Laws Tue, 02 Apr 1935 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=193344