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    <title>2019 (9) TMI 313 - MADRAS HIGH COURT</title>
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    <description>The Tribunal ruled that the amount received by the assessee towards corpus from the employer cannot be treated as income. Reopening of assessments under Section 147 was deemed invalid as it was based on a change of opinion without new tangible material. The revenue&#039;s appeal was dismissed as infructuous due to the invalidated reassessment proceedings. The Tribunal upheld the allowance of proportionate expenditure against the corpus receipt as revenue expenditure. The appeals by the Revenue were dismissed, and the original assessments treating the corpus as non-taxable were upheld.</description>
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      <link>https://www.taxtmi.com/caselaws?id=385545</link>
      <description>The Tribunal ruled that the amount received by the assessee towards corpus from the employer cannot be treated as income. Reopening of assessments under Section 147 was deemed invalid as it was based on a change of opinion without new tangible material. The revenue&#039;s appeal was dismissed as infructuous due to the invalidated reassessment proceedings. The Tribunal upheld the allowance of proportionate expenditure against the corpus receipt as revenue expenditure. The appeals by the Revenue were dismissed, and the original assessments treating the corpus as non-taxable were upheld.</description>
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      <pubDate>Mon, 05 Aug 2019 00:00:00 +0530</pubDate>
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