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    <title>1992 (10) TMI 17 - BOMBAY High Court</title>
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    <description>Deemed income provisions for annuity deposits were construed strictly: repayment under the annuity deposit scheme was taxable only in the hands of the depositor because the charging fiction in section 2(24)(viii) covered only the annuity due or commuted value paid under section 280D. Nomination under the scheme did not widen that fiction, and in the absence of an express charging provision the provision could not be extended by analogy or equity to a nominee or legal heir. Repayment received by a nominee or legal heir was therefore not taxable as income under the stated provisions, and the contrary view was rejected.</description>
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    <pubDate>Fri, 09 Oct 1992 00:00:00 +0530</pubDate>
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      <title>1992 (10) TMI 17 - BOMBAY High Court</title>
      <link>https://www.taxtmi.com/caselaws?id=20371</link>
      <description>Deemed income provisions for annuity deposits were construed strictly: repayment under the annuity deposit scheme was taxable only in the hands of the depositor because the charging fiction in section 2(24)(viii) covered only the annuity due or commuted value paid under section 280D. Nomination under the scheme did not widen that fiction, and in the absence of an express charging provision the provision could not be extended by analogy or equity to a nominee or legal heir. Repayment received by a nominee or legal heir was therefore not taxable as income under the stated provisions, and the contrary view was rejected.</description>
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      <pubDate>Fri, 09 Oct 1992 00:00:00 +0530</pubDate>
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