https://www.taxtmi.com/caselaws?id=49582 An administrative assurance confined to income-tax, super-tax and excess profits tax could not extend exemption to business profits tax, especially after the statutory exemption power had been curtailed; the exemption claim therefore failed. A payment made under a business arrangement to meet administrative expenses and secure services was not a subsidy, because a subsidy is a bounty or benevolent grant rather than consideration for services or reimbursement of business costs; the amount was accordingly taxable. The legal position stated is that exemption cannot be enlarged beyond its terms by administrative letter, and commercial payments for expenses or services do not fall within a subsidy exemption. en-us Wed, 30 Mar 1960 00:00:00 +0530 Wed, 03 Sep 2014 11:44:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=49582 An administrative assurance confined to income-tax, super-tax and excess profits tax could not extend exemption to business profits tax, especially after the statutory exemption power had been curtailed; the exemption claim therefore failed. A payment made under a business arrangement to meet administrative expenses and secure services was not a subsidy, because a subsidy is a bounty or benevolent grant rather than consideration for services or reimbursement of business costs; the amount was accordingly taxable. The legal position stated is that exemption cannot be enlarged beyond its terms by administrative letter, and commercial payments for expenses or services do not fall within a subsidy exemption. Case-Laws Income Tax Wed, 30 Mar 1960 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=49582