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december 1962

Supreme Court of India · 1962-12-11

P. H. DIVECHA AND ANOTHER vs COMMISSIONER OF INCOME-TAX,BOMBAY I

Citation / case number
SC 1961/254
Court
Supreme Court of India
Petitioner
P. H. DIVECHA AND ANOTHER
Respondent
COMMISSIONER OF INCOME-TAX,BOMBAY I
Author
DAS, S.K.,KAPURL.,SARKAR, A.K.,HIDAYATULLAH, M.,DAYAL, RAGHUBAR
Bench
DAS, S.K.,KAPUR, J.L.,SARKAR, A.K.,HIDAYATULLAH, M.,DAYAL, RAGHUBAR

Judgment text excerpt

The Supreme Court held that the payments received by the partners of the firm under the transition agreement with Phillips Electric Co. were taxable under Section 10(5A) of the Indian Income Tax Act, 1922. The Court ruled that the payments were not compensation for the termination of a trading agreement but rather constituted a taxable receipt. The High Court's decision to classify the payments as taxable was upheld, affirming that they did not qualify for exemption under Section 4(3)(VII).

P. H. DIVECHA AND ANOTHER vs COMMISSIONER OF INCOME-TAX,BOMBAY I · Niyam