https://www.taxtmi.com/caselaws?id=798896 Book profit for partners' remuneration includes commercial profit credited to the profit and loss account on transfer of a depreciable business asset, even where the amount is deemed short-term capital gain for capital-gains computation. Explanation 3 to Section 40(b) relies on net profit shown in the profit and loss account, computed under Chapter IV-D, subject to the prescribed remuneration adjustment; it does not exclude every receipt assessed under another income head. Section 50's deeming fiction is confined to capital-gains computation and does not displace commercial profit for book-profit purposes. Revenue neutrality cannot create a deduction, but actual payment and taxation of otherwise permissible remuneration may support its bona fide character. en-us Wed, 02 Sep 2026 00:00:00 +0530 Mon, 14 Sep 2026 08:32:12 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=798896 Book profit for partners' remuneration includes commercial profit credited to the profit and loss account on transfer of a depreciable business asset, even where the amount is deemed short-term capital gain for capital-gains computation. Explanation 3 to Section 40(b) relies on net profit shown in the profit and loss account, computed under Chapter IV-D, subject to the prescribed remuneration adjustment; it does not exclude every receipt assessed under another income head. Section 50's deeming fiction is confined to capital-gains computation and does not displace commercial profit for book-profit purposes. Revenue neutrality cannot create a deduction, but actual payment and taxation of otherwise permissible remuneration may support its bona fide character. Case-Laws Income Tax Wed, 02 Sep 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=798896