https://www.taxtmi.com/caselaws?id=27119 The High Court ruled in favor of the Department regarding the first issue, determining that the receipt of Rs. 8,19,495 was a business receipt, not a casual one, hence not exempt under section 10(3) of the Income-tax Act, 1961. However, in the second issue, the court sided with the assessee, allowing the unabsorbed depreciation of Rs. 5,16,795 to be carried forward and set off against Indian income for the assessment year 1967-68. The judgment highlighted the separate taxation of Indian and Pakistan incomes under the Avoidance of Double Taxation Agreement, resulting in both parties bearing their own costs. en-us Fri, 03 May 1985 00:00:00 +0530 Wed, 10 Feb 2010 17:57:31 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=27119 The High Court ruled in favor of the Department regarding the first issue, determining that the receipt of Rs. 8,19,495 was a business receipt, not a casual one, hence not exempt under section 10(3) of the Income-tax Act, 1961. However, in the second issue, the court sided with the assessee, allowing the unabsorbed depreciation of Rs. 5,16,795 to be carried forward and set off against Indian income for the assessment year 1967-68. The judgment highlighted the separate taxation of Indian and Pakistan incomes under the Avoidance of Double Taxation Agreement, resulting in both parties bearing their own costs. Case-Laws Income Tax Fri, 03 May 1985 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=27119