https://www.taxtmi.com/caselaws?id=9514 A prior Supreme Court ruling bound the parties only to the legal principle and facts actually decided, and did not create an absolute rule that all first-year subscriptions must be treated as capital receipts. On the facts, the Tribunal erred in treating the subscriptions for the relevant assessment years as capital receipts because they were substantially appropriated as income and not shown as refundable liabilities. The 1987 Reserve Bank directions were held to operate prospectively from 15 May 1987, so they applied to pending proceedings only for deposits after that date and not retrospectively to earlier subscriptions. The reference was answered against the assessee. en-us Thu, 06 Oct 2005 00:00:00 +0530 Tue, 02 May 2023 17:00:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=9514 A prior Supreme Court ruling bound the parties only to the legal principle and facts actually decided, and did not create an absolute rule that all first-year subscriptions must be treated as capital receipts. On the facts, the Tribunal erred in treating the subscriptions for the relevant assessment years as capital receipts because they were substantially appropriated as income and not shown as refundable liabilities. The 1987 Reserve Bank directions were held to operate prospectively from 15 May 1987, so they applied to pending proceedings only for deposits after that date and not retrospectively to earlier subscriptions. The reference was answered against the assessee. Case-Laws Income Tax Thu, 06 Oct 2005 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=9514