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1989 (6) TMI 89 - ITAT DELHI-DExtract: .......er the quality of the receipt from the standpoint of the recipient. 9. Looking to the totality of the circumstances and peculiar facts in the background of this dispute, the sum of US Dollar 5,000 received by Prof. Menon could not be subjected to tax. Action of the CIT (Appeals) is hereby reversed and in the result the assessee s appeal is allowed.
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