https://www.taxtmi.com/caselaws?id=58931 A payment required under a gift deed was not deductible from business income as diversion of income by overriding title. The obligation was payable only out of income after accrual, so it operated as an application of income rather than a pre-accrual diversion. The alleged gift was also found to be incomplete because the sum was not effectively delivered or placed beyond the assessee's control, and the deed did not create an enforceable charge on the business profits. On that basis, the deduction claim failed and the disallowance was sustained. en-us Fri, 06 Sep 1985 00:00:00 +0530 Sun, 08 May 2011 14:02:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=58931 A payment required under a gift deed was not deductible from business income as diversion of income by overriding title. The obligation was payable only out of income after accrual, so it operated as an application of income rather than a pre-accrual diversion. The alleged gift was also found to be incomplete because the sum was not effectively delivered or placed beyond the assessee's control, and the deed did not create an enforceable charge on the business profits. On that basis, the deduction claim failed and the disallowance was sustained. Case-Laws Income Tax Fri, 06 Sep 1985 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=58931