https://www.taxtmi.com/caselaws?id=49443 Whether sums labelled salami for granting sub-leases are trading receipts under income-tax law is examined by reference to the capital-versus-revenue distinction and statutory heads of income. The analysis emphasises that mere realisation of fixed capital is excluded from income, but repeated acquisition, development and parceling of mineral rights and frequent grant of sub-leases under company objects showing intention to turn rights into account converts receipts into trading receipts. Accordingly, enhanced salami paid for sub-leases is treated as profits of a business rather than a capital realisation. en-us Thu, 31 Aug 1961 00:00:00 +0530 Fri, 29 Aug 2014 12:24:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=49443 Whether sums labelled salami for granting sub-leases are trading receipts under income-tax law is examined by reference to the capital-versus-revenue distinction and statutory heads of income. The analysis emphasises that mere realisation of fixed capital is excluded from income, but repeated acquisition, development and parceling of mineral rights and frequent grant of sub-leases under company objects showing intention to turn rights into account converts receipts into trading receipts. Accordingly, enhanced salami paid for sub-leases is treated as profits of a business rather than a capital realisation. Case-Laws Income Tax Thu, 31 Aug 1961 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=49443