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The High Court of Allahabad ruled in favor of the assessee, a Hindu undivided family, stating that the profits from the sale of jewelry to foreigners were not taxable as income. The Income-tax Appellate Tribunal found that the jewelry sold was not part of the family's business stock-in-trade and the transactions were not business-related. The court upheld the Tribunal's findings, concluding that the profits did not qualify as income under the Income-tax Act, 1961.
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