https://www.taxtmi.com/caselaws?id=18615 A partnership deed cannot, by itself, justify deduction of a share of profits paid to an institution unless there is a supporting legal basis and the payment operates as a diversion at source. Where the deed does not create an overriding charge on the profits, the income first accrues to the partners and is only thereafter applied to make the payment. On that reasoning, the amount is treated as an application of income, not a deductible diversion at source, and the claimed deduction was not allowable. en-us Thu, 30 Nov 1995 00:00:00 +0530 Fri, 30 Oct 2009 17:15:41 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=18615 A partnership deed cannot, by itself, justify deduction of a share of profits paid to an institution unless there is a supporting legal basis and the payment operates as a diversion at source. Where the deed does not create an overriding charge on the profits, the income first accrues to the partners and is only thereafter applied to make the payment. On that reasoning, the amount is treated as an application of income, not a deductible diversion at source, and the claimed deduction was not allowable. Case-Laws Income Tax Thu, 30 Nov 1995 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=18615