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    <title>1966 (2) TMI 97 - ALLAHABAD HIGH COURT</title>
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    <description>Article 363 did not bar the High Court from answering a statutory reference under the Income-tax Act because the court was only giving an advisory opinion on legal questions, not adjudicating the underlying covenant dispute. The former ruler also had no immunity from income-tax under international law after the lapse of paramountcy, as the State lacked international personality and the claimed sovereign immunity was not established. The merger agreement likewise did not continue any income-tax immunity, since it preserved only personal rights, privileges, immunities, dignities and titles and could not displace the charging provisions of the Act without a clear statutory exemption.</description>
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    <pubDate>Wed, 23 Feb 1966 00:00:00 +0530</pubDate>
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      <title>1966 (2) TMI 97 - ALLAHABAD HIGH COURT</title>
      <link>https://www.taxtmi.com/caselaws?id=291494</link>
      <description>Article 363 did not bar the High Court from answering a statutory reference under the Income-tax Act because the court was only giving an advisory opinion on legal questions, not adjudicating the underlying covenant dispute. The former ruler also had no immunity from income-tax under international law after the lapse of paramountcy, as the State lacked international personality and the claimed sovereign immunity was not established. The merger agreement likewise did not continue any income-tax immunity, since it preserved only personal rights, privileges, immunities, dignities and titles and could not displace the charging provisions of the Act without a clear statutory exemption.</description>
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      <pubDate>Wed, 23 Feb 1966 00:00:00 +0530</pubDate>
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