https://www.taxtmi.com/caselaws?id=49655 Receipt from restructuring a managing agency arrangement was not taxable as capital gains because the transaction, on the agreed facts, amounted to relinquishment under a substituted arrangement rather than a sale or transfer of a capital asset. The original correspondence contemplated a transfer, but a later letter modified the arrangement so that the assessee would resign and give up the managing agency instead of assigning it. As taxing provisions must be strictly construed, section 12B could apply only if the receipt arose from a sale or transfer. It did not, so capital gains tax was not attracted. en-us Wed, 15 May 1957 00:00:00 +0530 Fri, 18 Feb 2022 14:18:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=49655 Receipt from restructuring a managing agency arrangement was not taxable as capital gains because the transaction, on the agreed facts, amounted to relinquishment under a substituted arrangement rather than a sale or transfer of a capital asset. The original correspondence contemplated a transfer, but a later letter modified the arrangement so that the assessee would resign and give up the managing agency instead of assigning it. As taxing provisions must be strictly construed, section 12B could apply only if the receipt arose from a sale or transfer. It did not, so capital gains tax was not attracted. Case-Laws Income Tax Wed, 15 May 1957 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=49655