The Income Tax Reports - A Journal of the Law of Income Tax with Reports of Indian and Select English Cases

It has been laid down in this case that the word profits ' is used in the notification of the Government which exempts the profits of co-operative societies from income tax in the sense of the surplus by which the receipts from the trade or business exceed the expenditure necessary for the purpose of earing those receipts and that prima facie therefore neither in-`--ist from securities nor in [...] R. 100] shows that royalty payable to the lessor which is appropriated by the lessee under the terms of the lease for reducing the amount of the loan advanceu by the lessee is income of the lessor. [...] Sir C. V. Anantakrishna Aiyar when he was the AdvocateGeneral of Madras realised the necessity of specialisation and brought to the notice of the Madras Government the desirability of appointing a Legal Adviser to the Commissioner of Income Tax. [...] COSTELLO J. said : Giving to the words of Section 14 (2) (a) their plain meaning and without a g to or subtracting from the words of the section itself we are L and to come to the conclusion whatever the result may be that there-has been assessment on the profits or gains of the copany which is sufficient to secure to the shareholders the whole of the dividends even though those dividends [...] in the' recipient's capacity of a member of the family whether the fact that the recipient was a member of the family was the cause of the payment.