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    <title>2021 (8) TMI 435 - KERALA HIGH COURT</title>
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    <description>Section 192 of the Income-tax Act, 1961 requires tax deduction at source from salary income, and the obligation depends on the character of the payment, not on the recipient&#039;s religious status or later use of the money; salaries paid to nuns and priests in educational institutions were therefore subject to TDS. The doctrine of diversion of income by overriding title did not apply because the salary first reached the recipient and was only thereafter applied under personal or ecclesiastical obligations. CBDT circulars could not create an exemption contrary to the statute, Article 25 was not infringed by lawful tax deduction, and long-standing non-deduction created no enforceable right against the statutory mandate.</description>
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