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    <description>Whether the disputed payment constituted a revenue receipt or proceeds of a capital asset was determined by analysing the contractual arrangement and contemporaneous transactions; the contract was treated as an ordinary trading contract for purchase of stock-in-trade rather than a sale of a capital source. A previously proposed financing/partnership arrangement did not ripen into a binding partnership and was superseded by an assignment of the contract benefit. Statutory reopening and reference provisions and the claimed exemption were considered, and the receipt was characterised as revenue and held liable to income tax.</description>
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