https://www.taxtmi.com/caselaws?id=37973 Compensation received for termination of a managing agency was treated as capital in nature because the managing agency formed part of the assessee's income-earning apparatus and its loss destroyed that source of income. However, the same receipt was taxable as deemed business income under the statutory fiction in section 28(ii), which applies to compensation connected with termination or modification of a managing agency regardless of the source of payment. The amount was also not wholly assessable in assessment year 1963-64 on a receipt basis, because under the mercantile system the relevant income accrued year by year and had to be attributed to the periods of accrual. en-us Fri, 14 Oct 1977 00:00:00 +0530 Fri, 02 Apr 2010 13:43:45 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=37973 Compensation received for termination of a managing agency was treated as capital in nature because the managing agency formed part of the assessee's income-earning apparatus and its loss destroyed that source of income. However, the same receipt was taxable as deemed business income under the statutory fiction in section 28(ii), which applies to compensation connected with termination or modification of a managing agency regardless of the source of payment. The amount was also not wholly assessable in assessment year 1963-64 on a receipt basis, because under the mercantile system the relevant income accrued year by year and had to be attributed to the periods of accrual. Case-Laws Income Tax Fri, 14 Oct 1977 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=37973