https://www.taxtmi.com/caselaws?id=28868 A subvention payment received by a non-resident's foreign associated company was held not to form part of profits taxable in India under rule 10(ii) of the Income-tax Rules, 1962. The Court noted that the payment was linked to reimbursement of losses on doubtful debts and that the Indian Income-tax Act contains no deeming provision treating such receipts as trading receipts, unlike the U.K. provision relied on. Because the underlying losses were not deductible and the receipt merely reimbursed those losses, it could not be characterised as business income or a trading receipt in the absence of a statutory deeming fiction. The receipt was therefore excluded from the taxable computation. en-us Tue, 13 Apr 1982 00:00:00 +0530 Mon, 08 Mar 2010 12:25:40 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=28868 A subvention payment received by a non-resident's foreign associated company was held not to form part of profits taxable in India under rule 10(ii) of the Income-tax Rules, 1962. The Court noted that the payment was linked to reimbursement of losses on doubtful debts and that the Indian Income-tax Act contains no deeming provision treating such receipts as trading receipts, unlike the U.K. provision relied on. Because the underlying losses were not deductible and the receipt merely reimbursed those losses, it could not be characterised as business income or a trading receipt in the absence of a statutory deeming fiction. The receipt was therefore excluded from the taxable computation. Case-Laws Income Tax Tue, 13 Apr 1982 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=28868