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    <title>1963 (12) TMI 43 - ALLAHABAD HIGH COURT</title>
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    <description>Interest credited to minors admitted to the benefits of a partnership is treated as income arising indirectly from that admission when the payments derive from capital invested (or loans treated as investments) by the minors; the critical test is whether the receipt is connected, directly or indirectly, with admission to partnership benefits. Characterisation of the minors&#039; payments as capital contribution or loan is a question of fact, and factual findings that the amounts were capital investments determine that the interest is includible in the father&#039;s total income under the applicable tax attribution rule.</description>
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    <pubDate>Wed, 18 Dec 1963 00:00:00 +0530</pubDate>
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      <title>1963 (12) TMI 43 - ALLAHABAD HIGH COURT</title>
      <link>https://www.taxtmi.com/caselaws?id=276557</link>
      <description>Interest credited to minors admitted to the benefits of a partnership is treated as income arising indirectly from that admission when the payments derive from capital invested (or loans treated as investments) by the minors; the critical test is whether the receipt is connected, directly or indirectly, with admission to partnership benefits. Characterisation of the minors&#039; payments as capital contribution or loan is a question of fact, and factual findings that the amounts were capital investments determine that the interest is includible in the father&#039;s total income under the applicable tax attribution rule.</description>
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      <pubDate>Wed, 18 Dec 1963 00:00:00 +0530</pubDate>
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