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    <title>1941 (12) TMI 26 - THE COURT OF APPEAL</title>
    <link>https://www.taxtmi.com/caselaws?id=276444</link>
    <description>Under section 18 of the Finance Act, 1936, the deeming rule was applied to charge the taxpayer on the entire income of the non-resident companies, not merely the portion actually enjoyed, because the extended concept of &quot;power to enjoy&quot; covered benefits arising from the income and the increased value of assets held for his benefit. Later amendment in the Finance Act, 1938 did not alter the meaning of the earlier provision, and the double taxation complaint failed because the son&#039;s income and the companies&#039; income were treated as distinct taxable subjects. The liability under the assessments therefore remained undisturbed.</description>
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    <pubDate>Tue, 16 Dec 1941 00:00:00 +0630</pubDate>
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      <title>1941 (12) TMI 26 - THE COURT OF APPEAL</title>
      <link>https://www.taxtmi.com/caselaws?id=276444</link>
      <description>Under section 18 of the Finance Act, 1936, the deeming rule was applied to charge the taxpayer on the entire income of the non-resident companies, not merely the portion actually enjoyed, because the extended concept of &quot;power to enjoy&quot; covered benefits arising from the income and the increased value of assets held for his benefit. Later amendment in the Finance Act, 1938 did not alter the meaning of the earlier provision, and the double taxation complaint failed because the son&#039;s income and the companies&#039; income were treated as distinct taxable subjects. The liability under the assessments therefore remained undisturbed.</description>
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      <pubDate>Tue, 16 Dec 1941 00:00:00 +0630</pubDate>
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