https://www.taxtmi.com/caselaws?id=29248 Sale proceeds from transfer of import entitlements under an export promotion scheme were held to be revenue receipts, not capital receipts. The Calcutta HC noted that the entitlements arose directly from the assessee's export business and could be used by the exporter or transferred to another eligible member for cash. Because the right was acquired in the course of carrying on the export business, the profit derived from dealing with that right formed part of the assessee's commercial operations. The decisive test was the nexus between the receipt and the business carried on, rather than whether the assessee was separately engaged in trading import entitlements. The receipts were therefore assessable as business income. en-us Mon, 02 Mar 1981 00:00:00 +0530 Thu, 11 Mar 2010 16:22:59 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=29248 Sale proceeds from transfer of import entitlements under an export promotion scheme were held to be revenue receipts, not capital receipts. The Calcutta HC noted that the entitlements arose directly from the assessee's export business and could be used by the exporter or transferred to another eligible member for cash. Because the right was acquired in the course of carrying on the export business, the profit derived from dealing with that right formed part of the assessee's commercial operations. The decisive test was the nexus between the receipt and the business carried on, rather than whether the assessee was separately engaged in trading import entitlements. The receipts were therefore assessable as business income. Case-Laws Income Tax Mon, 02 Mar 1981 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=29248