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    <title>1953 (1) TMI 2 - Supreme Court</title>
    <link>https://www.taxtmi.com/caselaws?id=49728</link>
    <description>Rule 5 of Schedule II to the Excess Profits Tax Act is explained as creating two deeming presumptions about even accrual of profits and the corresponding effect on capital employed, and the qualifying words &quot;so far as the contrary is shown&quot; are said to govern both presumptions, allowing rebuttal of each. The note also distinguishes debt from borrowed money under Schedule II: managing agency commission that remains unpaid under the agreement is treated as a debt under Rule 2, not borrowed money under Rule 2A, unless there is a clear lending arrangement converting the liability into a loan. On that reasoning, both substantive points are stated against the assessee.</description>
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    <pubDate>Fri, 16 Jan 1953 00:00:00 +0530</pubDate>
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      <title>1953 (1) TMI 2 - Supreme Court</title>
      <link>https://www.taxtmi.com/caselaws?id=49728</link>
      <description>Rule 5 of Schedule II to the Excess Profits Tax Act is explained as creating two deeming presumptions about even accrual of profits and the corresponding effect on capital employed, and the qualifying words &quot;so far as the contrary is shown&quot; are said to govern both presumptions, allowing rebuttal of each. The note also distinguishes debt from borrowed money under Schedule II: managing agency commission that remains unpaid under the agreement is treated as a debt under Rule 2, not borrowed money under Rule 2A, unless there is a clear lending arrangement converting the liability into a loan. On that reasoning, both substantive points are stated against the assessee.</description>
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      <pubDate>Fri, 16 Jan 1953 00:00:00 +0530</pubDate>
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