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    <title>1959 (7) TMI 60 - BOMBAY HIGH COURT</title>
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    <description>Section 7 of the Income-tax Act taxed salary, wages, commissions, perquisites and profits in lieu of salary, but Explanation 2 treated payments from an employer or former employer as taxable only unless they were made solely as compensation for loss of employment and not as remuneration for past services. On that basis, a share allotment made to an employee on termination of employment was analysed by its substance, and the employee&#039;s immediate re-employment did not change its character. Where the payment was in substance compensation for loss of employment, it was not taxable as salary or profits in lieu of salary. The stated amount was therefore not assessable as income or a revenue receipt.</description>
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      <title>1959 (7) TMI 60 - BOMBAY HIGH COURT</title>
      <link>https://www.taxtmi.com/caselaws?id=276789</link>
      <description>Section 7 of the Income-tax Act taxed salary, wages, commissions, perquisites and profits in lieu of salary, but Explanation 2 treated payments from an employer or former employer as taxable only unless they were made solely as compensation for loss of employment and not as remuneration for past services. On that basis, a share allotment made to an employee on termination of employment was analysed by its substance, and the employee&#039;s immediate re-employment did not change its character. Where the payment was in substance compensation for loss of employment, it was not taxable as salary or profits in lieu of salary. The stated amount was therefore not assessable as income or a revenue receipt.</description>
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