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    <title>2024 (4) TMI 880 - ITAT COCHIN</title>
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    <description>Interest received on enhanced compensation under section 28 of the Land Acquisition Act, 1894 was treated as taxable income from other sources under section 56(2)(viii) of the Income-tax Act, 1961, with the corresponding deduction mechanism under section 57(iv). The later statutory provision was applied despite earlier authority treating section 28 interest as part of compensation, because a receipt may remain capital in character yet still be taxed by legislative fiction. On that basis, the assessment could not be said to contain a mistake apparent from the record, so rectification under section 154 was not justified and the assessee&#039;s claim for exemption failed.</description>
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      <title>2024 (4) TMI 880 - ITAT COCHIN</title>
      <link>https://www.taxtmi.com/caselaws?id=751699</link>
      <description>Interest received on enhanced compensation under section 28 of the Land Acquisition Act, 1894 was treated as taxable income from other sources under section 56(2)(viii) of the Income-tax Act, 1961, with the corresponding deduction mechanism under section 57(iv). The later statutory provision was applied despite earlier authority treating section 28 interest as part of compensation, because a receipt may remain capital in character yet still be taxed by legislative fiction. On that basis, the assessment could not be said to contain a mistake apparent from the record, so rectification under section 154 was not justified and the assessee&#039;s claim for exemption failed.</description>
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