https://www.taxtmi.com/caselaws?id=430149 Where a government-framed scheme fixes the recipient's margin and requires the balance to be transferred to designated development funds, the surplus is diverted at source by overriding title and does not form taxable income. Promotional expenditure out of profits was not allowable under section 36(1)(xii) for the year in question because the statutory conditions and notification applied only from a later assessment year. Service charges were not taxed on accrual basis where the assessee consistently followed receipt basis due to recovery uncertainty. A deduction for education cess was also unavailable because the retrospective amendment negatived the claim for the relevant year. en-us Wed, 24 Aug 2022 00:00:00 +0530 Sat, 12 Nov 2022 12:32:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=430149 Where a government-framed scheme fixes the recipient's margin and requires the balance to be transferred to designated development funds, the surplus is diverted at source by overriding title and does not form taxable income. Promotional expenditure out of profits was not allowable under section 36(1)(xii) for the year in question because the statutory conditions and notification applied only from a later assessment year. Service charges were not taxed on accrual basis where the assessee consistently followed receipt basis due to recovery uncertainty. A deduction for education cess was also unavailable because the retrospective amendment negatived the claim for the relevant year. Case-Laws Income Tax Wed, 24 Aug 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=430149