https://www.taxtmi.com/caselaws?id=274370 Payments made under deeds of covenant to a charitable body were examined on their substance and held not to be exempt annual payments under section 447(1)(b) where they secured appreciable membership benefits and assurances. The promised continuing membership, protection against increased subscriptions, and access to club-like amenities were real counter-stipulations, not trifling or illusory advantages. On that basis, the sums could not be treated as pure income payments or pure gifts in the hands of the charity, and the de minimis principle did not apply to disregard the benefits. en-us Tue, 28 May 1957 00:00:00 +0530 Fri, 10 Aug 2018 12:35:34 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=274370 Payments made under deeds of covenant to a charitable body were examined on their substance and held not to be exempt annual payments under section 447(1)(b) where they secured appreciable membership benefits and assurances. The promised continuing membership, protection against increased subscriptions, and access to club-like amenities were real counter-stipulations, not trifling or illusory advantages. On that basis, the sums could not be treated as pure income payments or pure gifts in the hands of the charity, and the de minimis principle did not apply to disregard the benefits. Case-Laws Income Tax Tue, 28 May 1957 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=274370