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    <title>1964 (1) TMI 72 - Madras High Court</title>
    <link>https://www.taxtmi.com/caselaws?id=290880</link>
    <description>Where foreign earnings are genuinely converted into capital assets and later realised, the remitted sale proceeds retain their capital character and are not assessable as income merely because they originated from profits. The assessee had earned income in Fiji, invested it in house property and other assets, and later remitted the proceeds after realisation; the Department failed to show any temporary investment or device to disguise income as capital. On those facts, the remittances were traceable to capital, not unassessed business profits, and were held to be non-taxable receipts.</description>
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    <pubDate>Wed, 01 Jan 1964 00:00:00 +0530</pubDate>
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      <title>1964 (1) TMI 72 - Madras High Court</title>
      <link>https://www.taxtmi.com/caselaws?id=290880</link>
      <description>Where foreign earnings are genuinely converted into capital assets and later realised, the remitted sale proceeds retain their capital character and are not assessable as income merely because they originated from profits. The assessee had earned income in Fiji, invested it in house property and other assets, and later remitted the proceeds after realisation; the Department failed to show any temporary investment or device to disguise income as capital. On those facts, the remittances were traceable to capital, not unassessed business profits, and were held to be non-taxable receipts.</description>
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      <law>Income Tax</law>
      <pubDate>Wed, 01 Jan 1964 00:00:00 +0530</pubDate>
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