https://www.taxtmi.com/caselaws?id=21978 The court determined that the payments in question constituted a case of diversion of income at source by an overriding title. As a result, the issue of whether the payments constituted expenditure on capital account or revenue expenditure did not need to be addressed. The court referenced previous decisions to support its finding that the agreements with the lenders were akin to a sub-partnership, leading to diversion by overriding title. The judgment concluded by answering the reference accordingly, with no order as to costs. en-us Thu, 04 Apr 1991 00:00:00 +0530 Sat, 05 Dec 2009 12:22:30 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=21978 The court determined that the payments in question constituted a case of diversion of income at source by an overriding title. As a result, the issue of whether the payments constituted expenditure on capital account or revenue expenditure did not need to be addressed. The court referenced previous decisions to support its finding that the agreements with the lenders were akin to a sub-partnership, leading to diversion by overriding title. The judgment concluded by answering the reference accordingly, with no order as to costs. Case-Laws Income Tax Thu, 04 Apr 1991 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=21978