https://www.taxtmi.com/caselaws?id=49301 A periodic allowance paid under an 1837 arrangement was not agricultural income because its immediate and effective source was the arrangement extinguishing proprietary rights, not land or revenue derived from land. The fact that the amount varied by reference to land revenue collections did not change its source. The alternative contention that the payment was capital in nature also failed because there was no material showing that it was an instalment discharge of a capital sum for the transferred title; on the facts, it was an annuity-like revenue receipt. The receipt was therefore taxable revenue income and not an exempt capital receipt. en-us Fri, 09 Apr 1965 00:00:00 +0530 Wed, 20 Aug 2014 09:12:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=49301 A periodic allowance paid under an 1837 arrangement was not agricultural income because its immediate and effective source was the arrangement extinguishing proprietary rights, not land or revenue derived from land. The fact that the amount varied by reference to land revenue collections did not change its source. The alternative contention that the payment was capital in nature also failed because there was no material showing that it was an instalment discharge of a capital sum for the transferred title; on the facts, it was an annuity-like revenue receipt. The receipt was therefore taxable revenue income and not an exempt capital receipt. Case-Laws Income Tax Fri, 09 Apr 1965 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=49301