https://www.taxtmi.com/caselaws?id=49532 Whether a payment received after merger was taxable under section 7(1) read with Explanation 2 turned on its characterisation as remuneration for past services or a personal testimonial. The analysis applied the principle that receipts which accrue by virtue of an office (causa causans being past service) are taxable as office-derived remuneration, whereas purely personal testimonials are not. The majority gave decisive weight to the payer's statements and surrounding circumstances over later contrary labels, concluding the payment arose from past official services and is therefore taxable under the cited provision. en-us Tue, 29 Nov 1960 00:00:00 +0530 Mon, 01 Sep 2014 12:39:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=49532 Whether a payment received after merger was taxable under section 7(1) read with Explanation 2 turned on its characterisation as remuneration for past services or a personal testimonial. The analysis applied the principle that receipts which accrue by virtue of an office (causa causans being past service) are taxable as office-derived remuneration, whereas purely personal testimonials are not. The majority gave decisive weight to the payer's statements and surrounding circumstances over later contrary labels, concluding the payment arose from past official services and is therefore taxable under the cited provision. Case-Laws Income Tax Tue, 29 Nov 1960 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=49532