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    <title>1962 (7) TMI 64 - MADRAS HIGH COURT</title>
    <link>https://www.taxtmi.com/caselaws?id=286184</link>
    <description>A receipt is not protected from tax merely because similar income was taxed in another person&#039;s hands; double taxation is barred only when the same income is taxed twice in the same hands and in the same juridical character, so the assessee&#039;s receipt remained taxable. The agreement also did not create a partnership or sub-partnership, because there was no joint carrying on of the managing agency business and no partnership inter se. It likewise did not amount to an association of persons, as the arrangement was only a covenant to pay a fraction of another&#039;s income and showed no common design or joint venture.</description>
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    <pubDate>Tue, 31 Jul 1962 00:00:00 +0530</pubDate>
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      <title>1962 (7) TMI 64 - MADRAS HIGH COURT</title>
      <link>https://www.taxtmi.com/caselaws?id=286184</link>
      <description>A receipt is not protected from tax merely because similar income was taxed in another person&#039;s hands; double taxation is barred only when the same income is taxed twice in the same hands and in the same juridical character, so the assessee&#039;s receipt remained taxable. The agreement also did not create a partnership or sub-partnership, because there was no joint carrying on of the managing agency business and no partnership inter se. It likewise did not amount to an association of persons, as the arrangement was only a covenant to pay a fraction of another&#039;s income and showed no common design or joint venture.</description>
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      <pubDate>Tue, 31 Jul 1962 00:00:00 +0530</pubDate>
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