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Showing 281 to 298 of 298 Records
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1992 (9) TMI 18
Issues:
1. Interpretation of deduction under section 80P(2)(a)(iv) for sales to non-members.
2. Granting deduction of entire gross profit under section 80P(2)(a)(iv).
Analysis:
The High Court of BOMBAY addressed the interpretation of deduction under section 80P(2)(a)(iv) for sales to non-members and the granting of the entire gross profit under the same section. The case involved a co-operative society engaged in various agricultural activities, including supplying commodities to both members and non-members. The Income-tax Officer contended that the original intention at the time of purchase of commodities determined the eligibility for deduction under section 80P(2)(a)(iv). The Tribunal, however, held that the intention at the time of purchase was irrelevant, and exemption applied to sales to members, irrespective of the original intention. The Court agreed with the Tribunal, emphasizing that the law grants exemption based on the actual sales of specified commodities to members, not the original intention at the time of purchase.
Regarding the deduction of the entire gross profit, the Court analyzed the definition of "profits and gains of business" under the Income-tax Act. It highlighted that the expression must be understood in the context of section 29, which governs the computation of income. The Court also referenced section 80AB, clarifying that it explains the pre-existing legal position and applies to the assessment year in question. The Court dismissed the applicability of previous decisions cited by the assessee, emphasizing the distinct provisions and factual backgrounds. Additionally, the Court discussed a Supreme Court decision on the interpretation of "attributable to" versus "derived from," noting that the distinction did not impact the current case.
In conclusion, the High Court ruled in favor of the Revenue for both questions raised. It held that the Tribunal's approach was erroneous, emphasizing that exemption under section 80P(2)(a)(iv) applied to actual sales to members and that the entire gross profit could not be claimed as a deduction. No costs were awarded in the judgment.
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1992 (9) TMI 17
Issues:
1. Validity of the order under section 23A of the Indian Income-tax Act, 1922 for the assessment year 1960-61.
2. Applicability of the scheme of amalgamation in the tax assessment proceedings.
3. Jurisdiction of the court to entertain a writ petition challenging tax assessment orders.
4. Authority to impose super-tax without issuing notice to the petitioner-company.
5. Power of the court to order refund of taxes collected without authority of law.
Analysis:
1. The writ petition was filed to challenge the order dated March 2, 1965, passed under section 23A of the Indian Income-tax Act, 1922, for the assessment year 1960-61. The petitioner sought withdrawal, cancellation, and refund of the tax amount paid. The amalgamation of two companies was a key factor in the assessment process.
2. Following the amalgamation sanctioned by the High Courts, the undertakings and obligations of the dissolved companies were transferred to the petitioner-company. Notices under section 23A were issued to the defunct companies, but the tax was imposed on the petitioner. The Tribunal held that the petitioner was the legal representative of the transferor companies, justifying the tax imposition.
3. The petitioner's appeals were dismissed by the Appellate Assistant Commissioner, and subsequent reference applications were rejected by the High Court of Delhi. The court held that the judgments of the tax authorities became final, and the assessment order was unassailable. The petitioner's challenge through a writ petition was deemed not maintainable.
4. The petitioner argued that the imposition of super-tax without issuing notice to the petitioner-company was unlawful, citing precedents for tax refund in such cases. However, the court held that appearing in the assessment proceedings waived the right to challenge the assessment based on lack of notice, and unlimited power for refund did not apply.
5. The court dismissed the writ petition, emphasizing that the petitioner's delay in filing the petition and participation in the assessment proceedings barred the claim for refund. The court clarified that unlawful collection of taxes does not automatically warrant a refund and upheld the tax assessment orders.
This detailed analysis covers the issues raised in the legal judgment, highlighting the key arguments and decisions made by the court regarding the tax assessment and refund claims.
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1992 (9) TMI 16
Issues:
Challenge to the order passed under section 132(5) of the Income-tax Act, 1961 on grounds of lack of jurisdiction, violation of natural justice, and non-compliance with procedural requirements.
Interplay between the availability of alternative remedies under section 132(11) and the right to file a writ petition.
Validity of the order under section 132(5) in light of various judicial precedents and legal provisions.
Analysis:
The appellant contended that the order passed under section 132(5) was flawed as it was issued without providing a reasonable opportunity and was based on incomplete information. Reference was made to the Gujarat High Court judgment emphasizing the importance of compliance with procedural requirements, specifically regarding the notice to show cause. Additionally, reliance was placed on other cases highlighting the significance of fair play and natural justice in such proceedings.
The appellant further argued that the Income-tax Officer exceeded jurisdiction by considering items not seized and by delaying the order beyond the prescribed timeline. Legal precedents, such as the Karnataka High Court judgment, were cited to support the argument that a valid seizure is a prerequisite for exercising powers under section 132(5) and any deviation renders the order liable to be quashed.
The court examined the provisions of section 132(11) and emphasized that the availability of an alternative remedy does not bar the filing of a writ petition. Citing the Supreme Court and various High Court judgments, it was established that the writ jurisdiction can be invoked if the authority's actions are beyond its powers or violate fundamental rights, even if alternative remedies exist.
Moreover, the court discussed the discretionary nature of rule 112A of the Income-tax Rules, 1962, and clarified that not every provision in a taxing statute is mandatory. The judgment highlighted that the Commissioner has the authority to review the validity of proceedings and consider objections raised by the assessee, ensuring a fair examination of facts and applicable laws.
In the present case, the court noted that the appellant had opportunities to explain the seized assets but failed to provide satisfactory explanations, leading to the order under section 132(5). The court emphasized that objections raised by the petitioner could be addressed under section 132(11) by the Commissioner, indicating that the order under section 132(5) is not conclusive and can be challenged during regular assessment proceedings.
Ultimately, the court dismissed the special appeal, affirming the availability of alternative remedies and the need for factual disputes to be resolved through the prescribed legal procedures. The appellant was granted a timeframe to file objections, emphasizing the importance of adhering to the statutory limitations.
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1992 (9) TMI 15
Issues:
1. Interpretation of section 80P(2)(a)(iv) of the Income-tax Act.
2. Determination of deduction entitlement for a co-operative society.
3. Application of original intention in assessing deduction eligibility.
4. Consideration of gross profit deduction under section 80P(2)(a)(iv).
5. Legal procedure for reference under section 256 of the Income-tax Act.
Analysis:
The High Court of Bombay addressed multiple issues in this judgment. The Commissioner of Income-tax sought a reference to the High Court regarding six questions related to the interpretation of section 80P(2)(a)(iv) of the Income-tax Act. The Tribunal partially allowed the application and referred two questions, focusing on the deduction entitlement of a co-operative society for sales to non-members and the application of the original intention in determining deduction eligibility. The Tribunal's decision was based on the original intention of the assessee at the time of purchase, rather than the ultimate disposition of the commodities.
In a similar case, the High Court had previously held that profits from actual sales to members fall under the exempted category of income under section 80P(2)(a)(iv), regardless of the original intention at the time of purchase. The Court clarified that the term "profits and gains" refer to income computed under section 29 of the Act, indicating that the entire profit without computation is not eligible for deduction. Consequently, the High Court answered the referred questions, with the first question being answered in the negative and in favor of the Revenue.
Regarding the legal procedure for reference under section 256 of the Income-tax Act, the Court considered a notice of motion pressed by the Revenue. Despite the possibility of directing the Tribunal to refer a question of law, the Court decided to record the answer without further reference due to the lengthy process involved. The Court emphasized the need to streamline procedures and avoid unnecessary litigation, especially when the matter had been conclusively settled. The Court highlighted the need for a more efficient approach to legal procedures, citing the burden on courts and tribunals.
In conclusion, the High Court decided to answer the question raised in the notice of motion without calling for a statement from the Tribunal, considering the matter's prolonged duration and the unnecessary procedural steps that would follow. The Court also addressed the submissions made by the counsel for the assessee, emphasizing the unique circumstances of the case and the need for a pragmatic approach to legal proceedings. The judgment ultimately favored the Revenue, with no costs awarded.
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1992 (9) TMI 14
Issues:
1. Interpretation of rental income from a house as assessable income of a Hindu undivided family.
2. Assessment of the value of a house and site under the Wealth-tax Act for a Hindu undivided family.
Interpretation of Rental Income:
The case involved a Hindu undivided family where a partition deed was executed in 1955, and a property was allotted to the assessee. The income from this property was not disclosed for tax purposes until 1971. The Revenue assessed the income and property value for various years. The Appellate Tribunal held that the income and property were rightly taxed. The assessee argued that a settlement in 1961 made the property joint family property, and thus, only a portion should be assessed. However, the Revenue contended that the partition in 1955 divided the family, and the property was not joint family property. The Tribunal found that the family ceased to exist after the partition deed, and the property belonged to the smaller Hindu undivided family of the assessee and his wife. The court agreed, stating that the property was rightly assessed in the hands of the smaller Hindu undivided family.
Assessment under Wealth-tax Act:
The Wealth-tax Officer assessed the capital value of the land and house for several years. The Appellate Assistant Commissioner allowed the appeal, but the Revenue appealed to the Tribunal, which upheld the assessment. The assessee argued that only one-fifth of the income and property value should be assessed. However, the Tribunal found that the property belonged to the smaller Hindu undivided family. The court agreed with the Tribunal's conclusion, stating that the property and income should be assessed in the hands of the smaller Hindu undivided family. Consequently, the questions were answered against the assessee and in favor of the Revenue, affirming the Tribunal's decision to tax the property and income in the hands of the smaller Hindu undivided family.
Conclusion:
The court upheld the Tribunal's decision to tax the rental income and property value in the hands of the smaller Hindu undivided family, rejecting the assessee's argument that only a portion should be assessed. The judgment clarified that the property belonged to the smaller Hindu undivided family, based on the facts and absence of evidence supporting the assessee's claims.
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1992 (9) TMI 13
Issues involved:
1. Interpretation of section 263 of the Income-tax Act regarding annulment of Commissioner's order.
2. Determination of whether there was a transfer of interest by the assessee to other partners within the meaning of section 2(47) of the Income-tax Act, 1961.
Interpretation of section 263 - Commissioner's Order:
The case involved a partnership named White Field Industrial Corporation, where land was purchased before the assessee became a partner. The assessee received Rs. 2 lakhs upon retirement, which the Commissioner deemed as a transfer liable to tax under section 263. The Tribunal, citing precedent, held that no transfer occurred as the land was acquired before the assessee joined the partnership. The Tribunal's decision was based on the judgment in CIT v. L. Raghu Kumar [1983] 141 ITR 674, which established that no transfer of interest in partnership assets occurs when a retiring partner withdraws an amount exceeding his capital and profits share. Consequently, the Tribunal ruled in favor of the assessee, concluding that no transfer took place under section 2(47) of the Act.
Transfer of Interest - Section 2(47) Interpretation:
The Tribunal's decision was supported by the legal principle that the withdrawal of an amount by a retiring partner at the time of retirement does not constitute a transfer of a capital asset to existing partners. This interpretation was based on the ruling in CIT v. L. Raghu Kumar [1983] 141 ITR 674 (AP), where it was established that such withdrawals do not attract capital gains tax as there is no transfer within the meaning of section 2(47) of the Act. Therefore, the second question regarding the transfer of interest was answered in favor of the assessee, leading to a consequential affirmation of the first question in favor of the assessee as well.
This judgment clarifies the application of section 263 of the Income-tax Act and the definition of transfer of interest under section 2(47) in the context of partnership withdrawals and retirement benefits.
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1992 (9) TMI 12
The High Court of Andhra Pradesh ruled that the fair market value of properties transferred by the assessee to his wife is not includible in his wealth under the Wealth-tax Act. The amount paid by the assessee to his wife towards meher amount cannot be considered a transfer without consideration, and thus, the property purchased from that amount cannot be included in the assessee's assets for wealth-tax purposes. The court answered the questions in favor of the assessee and against the Revenue.
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1992 (9) TMI 11
Issues:
1. Validity of transfer of immovable property by means of book entries without registration under the Transfer of Property Act, 1882.
2. Assessment of capital gains in the hands of a partnership firm.
Analysis:
Issue 1: Validity of Transfer of Immovable Property
The case involved a partnership firm that purchased a plot of land, later transferred out of the firm through book entries and subsequently sold. The Income-tax Officer assessed capital gains in the hands of the firm, contending that the transfer without a registered document was invalid. The Tribunal, however, upheld the transfer as valid, citing the decision in Malabar Fisheries Co. v. CIT. The High Court analyzed the legal framework, emphasizing that during the subsistence of a partnership, partners do not have individual rights over firm property. The court referred to provisions of the Indian Partnership Act, Transfer of Property Act, and Indian Registration Act to assert that a registered document is necessary for a valid transfer of immovable property. The court rejected the argument that the transfer merely involved partners holding property in proportion to their share, emphasizing the need for a formal transfer document.
Issue 2: Assessment of Capital Gains
The court addressed the assessment of capital gains in the hands of the partnership firm. It highlighted the distinction between the situation upon dissolution of a firm, as discussed in the Malabar Fisheries Co. case, and the transfer of firm property during the partnership. The court emphasized that common immovable properties cannot be divided without a registered document, as it involves a transfer of interest. The judgment referenced decisions from various High Courts supporting the requirement of a registered document for such transfers. The court rejected the argument that the transaction did not amount to a transfer, emphasizing the legal necessity of a registered document for property transfers.
In conclusion, the High Court answered the first question regarding the validity of the transfer in the negative, in favor of the Revenue. It also answered the second question on the assessment of capital gains in the affirmative, again in favor of the Revenue. No costs were awarded in the case.
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1992 (9) TMI 10
The High Court of Bombay considered a case where the Appellate Tribunal had set aside an ex parte assessment by the Income-tax Officer. The Tribunal held that the setting aside was limited to a specific issue. However, the High Court disagreed, stating that the Income-tax Officer's scope of inquiry was not restricted. The Court ruled in favor of the Revenue.
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1992 (9) TMI 9
The High Court of Bombay rejected an application under section 256(2) of the Income-tax Act, 1961, regarding investment allowance eligibility. The Tribunal's decision was upheld, stating that there was no mistake apparent on the face of the record. The court also cited relevant case law to support its decision. The application was ultimately rejected with no costs awarded.
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1992 (9) TMI 8
Issues:
- Claim of investment allowance for a hotel under section 32A of the Income-tax Act, 1961
- Disallowance of luxury tax liability deduction for earlier years
Analysis:
1. Investment Allowance Claim:
- The assessee, operating a five-star hotel, claimed investment allowance for plant and machinery installed during the assessment years 1978-79 and 1979-80.
- The Income-tax Officer denied the allowance, stating that the hotel business did not qualify as an industrial undertaking under section 32A as it did not involve manufacturing or production.
- The Commissioner of Income-tax (Appeals) upheld the denial based on the Kerala High Court judgment in CIT v. Casino (Pvt.) Ltd.
- The Tribunal, however, allowed the investment allowance, considering the preparation of food in the hotel as a manufacturing activity, citing precedents like Orient Express Co. (P.) Ltd. v. IAC of I. T.
- The Tribunal directed the Income-tax Officer to verify and allow investment allowance only for machinery or plant involved in the production of food.
- The High Court, following a previous decision in CIT v. S. P. Jaiswal Estates (P.) Ltd., ruled against the assessee on the investment allowance claim.
2. Luxury Tax Liability Deduction:
- The assessee contested a luxury tax liability of Rs. 1,66,981 for earlier years, challenging the validity of the luxury tax Act.
- The Income-tax Officer disallowed the deduction, stating that the liability existed in previous accounting years and should have been claimed then.
- The Commissioner of Income-tax (Appeals) upheld the disallowance due to the absence of a provision for the liability despite the assessee's awareness.
- The Tribunal allowed the deduction, directing the Income-tax Officer to modify the assessment accordingly.
- The High Court, following the principle established by the Supreme Court in Kedarnath Jute Manufacturing Co. Ltd. v. CIT, held that the liability crystallizes when the taxable event occurs, irrespective of the assessee contesting the liability.
- The High Court ruled against the assessee on the luxury tax liability deduction, aligning with the Supreme Court's decision and rejecting the claim.
In conclusion, the High Court dismissed the assessee's claims for investment allowance and luxury tax liability deduction based on precedents and established legal principles. The judgments were delivered by Judges Shyamal Kumar Sen and Ajit K. Sengupta.
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1992 (9) TMI 7
Issues Involved:
1. Whether the return filed on May 24, 1971, could be treated as a revised return u/s 139(5) of the Income-tax Act.
2. Whether the CBDT circular amounted to a promise that penalty will not be imposed if a revised return offering concealed income is filed.
3. Whether the Inspecting Assistant Commissioner could impose penalty despite the CBDT advertisement dated January 5, 1971.
4. Whether penalty was imposable by the Inspecting Assistant Commissioner in relation to income deemed from undisclosed sources.
5. Whether the provisions of the Explanation to section 271(1)(c) are applicable given the income declared in the return filed on May 24, 1971.
Summary:
Issue 1: Revised Return u/s 139(5)
The court held that the return filed on May 24, 1971, is a "revised return" as contemplated u/s 139(5) of the Income-tax Act. The incorrectness in the original return had not been discovered by the Income-tax Officer, and the revised return was filed before any discoveries of evasion were made. The Department, having assessed the income based on that return, cannot claim it was not a revised return. The Department's stand amounts to "approbate and reprobate," which is not permissible in law.
Issue 2: CBDT Circular as a Promise
The court concluded that the CBDT circular issued on January 5, 1971, has the status of "orders, instructions, and directions" u/s 119 of the Act. The advertisement was a general relaxation in the matter of imposition of penalty u/s 271, aimed at collecting more revenue by incentivizing the public to disclose suppressed income. The court emphasized that such circulars are binding on the officers of the Department and must be adhered to.
Issue 3: Imposition of Penalty Despite CBDT Advertisement
The court held that it was not open to the Inspecting Assistant Commissioner to impose a penalty under the circumstances. The advertisement amounted to a promise that penalty would not be imposed for concealing income if it was offered for assessment before its discovery by the Department. The court stressed the importance of the Department's reliability and the need to honor such promises.
Issue 4: Penalty for Income from Undisclosed Sources
The court did not find justification for imposing a penalty in relation to income deemed from undisclosed sources, given the revised return filed before any actual discovery by the Department.
Issue 5: Applicability of Explanation to Section 271(1)(c)
The Department agreed that the income returned is more than 80% of the assessed income, thus the Explanation to section 271(1)(c) is not attracted. Consequently, the question of penalty will have to be adjudicated without the deeming provisions of the Explanation.
Answers to Questions:
1. In the affirmative and in favor of the assessee.
2. In the affirmative and in favor of the assessee.
3. In the negative and in favor of the assessee.
4. Explanation to section 271(1)(c) does not apply.
5. Explanation to section 271(1)(c) does not apply.
No order as to costs.
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1992 (9) TMI 6
Issues involved:
The issue involves the claim of initial depreciation by the assessee for plant and machinery not put to use during the year, under section 32(1)(vi) of the Income-tax Act, 1961.
Judgment Details:
The High Court of Bombay considered the assessee's reference under section 256(1) of the Income-tax Act, 1961, regarding the disallowance of the claim for initial depreciation on machinery not put to use during the relevant year. The machinery in question, including a crankshaft grinding machine and an air compressor, was installed in 1975, but production commenced in 1977. The Income-tax Officer denied the allowance citing non-fulfillment of conditions in section 32(1)(vi) as the machinery was not utilized in the accounting year preceding the assessment year.
The court analyzed section 32(1) which allows deductions for depreciation of assets used for business purposes owned by the assessee. It was observed that as per the language of clause (vi), depreciation allowance is contingent upon actual use of the machinery for the business. Referring to a Gujarat High Court decision, it was emphasized that unless the machinery is put to use for the business, depreciation allowance cannot be granted.
The court rejected the argument that the assessee could choose to claim depreciation either in the year of installation or the year of first use for business purposes. The scheme indicates that deduction can be claimed for the assessment year relevant to the previous year when the machinery was installed and used for business. If there is a gap of more than one clear previous year between installation and use, no depreciation can be claimed.
Various precedents were cited to distinguish the interpretation of "use" in different sections of the Income-tax Act, emphasizing that the context and objectives of each provision differ. Ultimately, the court answered the question in the affirmative and in favor of the Revenue, denying the depreciation claim for the year in question. No costs were awarded in this matter.
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1992 (9) TMI 5
Issues:
- Deduction claim for commission paid to husband as business expenditure for assessment years 1974-75 and 1975-76.
- Contradictory views by Appellate Assistant Commissioner for both assessment years.
- Tribunal's refusal to allow additional evidence.
- Lack of material supporting Tribunal's findings.
Analysis:
The case involved a dispute regarding the deduction claim for the commission paid by the assessee to her husband as business expenditure for the assessment years 1974-75 and 1975-76. The Income-tax Officer disallowed the claim initially, but the Appellate Assistant Commissioner reversed the decision for the year 1974-75, citing the husband's influence in procuring work and generating profits for the factory. However, for the year 1975-76, the Appellate Assistant Commissioner upheld the disallowance, questioning the clarity on the business items influenced by the husband and his role as a paid employee. This led to contradictory views by the Appellate Assistant Commissioner for the two assessment years.
The Tribunal, in its decision, did not allow the assessee to present additional evidence during the hearing, stating lack of reasons for not submitting the evidence earlier. The Tribunal emphasized the absence of substantial material supporting the claim that the husband's influence resulted in increased business for the assessee. The Tribunal affirmed the Income-tax Officer's orders for both assessment years based on the lack of evidence and the standard practice of business distribution by the marketing federation.
In light of the contradictory views and the denial of additional evidence by the Tribunal, the High Court directed a remand of the case to the Tribunal. Citing the Calcutta High Court judgment in Vishnu Agencies (P.) Ltd. v. CIT, the High Court emphasized the need for fairness and justice in allowing the assessee to submit additional documents and giving the Revenue an opportunity to support its case. The High Court instructed the Tribunal to reconsider the matter, allowing both parties to present their respective materials before deciding on the nature of the commission paid by the assessee to her husband for the assessment years in question.
Therefore, the High Court remanded the case to the Tribunal for further proceedings, emphasizing the importance of allowing the submission of additional evidence and ensuring a fair and just determination of whether the commission paid to the husband qualifies as business expenditure for the relevant assessment years.
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1992 (9) TMI 4
Issues involved:
The judgment addresses two main issues:
1. Whether the voluntary disclosure petition made by the assessee was within time.
2. Whether a certificate under section 8(2) of the Voluntary Disclosure of Income and Wealth Act, 1976, was a condition precedent for non-inclusion of the disclosed income.
Issue 1: Voluntary Disclosure Petition Timing:
The assessee contended that a deposit of Rs. 40,000 in December 1975 was earned over the past 10 years, not during the previous year. A disclosure petition was sent on December 30, 1975, but received on January 1, 1976. The Income-tax Officer treated Rs. 40,000 as income from undisclosed sources for the assessment year 1977-78. The Tribunal allowed the appeal, stating the disclosure was within time for benefits under the Ordinance. The court interpreted the word "before" in section 3(1) of the Ordinance to mean "up to" or "not after," citing precedents where "before" signified "up to." The legislative intent indicated the time limit extended until January 1, 1976, preserving the taxpayer's rights.
Issue 2: Certificate Requirement for Relief:
Section 8(1) of the Ordinance outlines three conditions for relief, including crediting the disclosed amount, paying income tax, and making required investments. The Tribunal was tasked with verifying if these conditions were met. The judgment clarified that obtaining a certificate under section 8(2) was not a condition precedent but a directive for the Commissioner to issue it upon application. The Tribunal correctly ruled that holding the certificate was not mandatory for granting relief.
In conclusion, both issues were resolved in favor of the assessee, affirming the timeliness of the disclosure petition and clarifying the non-mandatory nature of the certificate under section 8(2).
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1992 (9) TMI 3
Whether the Tribunal was right in holding that the Income-tax Officer was not justified in invoking the provisions of section 52(2) of the Income-tax Act, 1961 - Whether the Tribunal was right in holding that the Income-tax Officer was not justified in disallowing the loss of ₹ 50,724 claimed by the assessee and in making an addition of ₹ 1,21,276 as short term capital gain on the basis of break up value of the shares on the date of transfer as the market value of shares
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1992 (9) TMI 2
Whether, on the facts and in the circumstances of the case, the Tribunal was justified in law in upholding the order of the Appellate Assistant Commissioner cancelling the penalty orders of the Income-tax Officer under section 271(1)(a) of the Income-tax Act, 1961, relating to the assessment years 1963-64 and 1964-65, on the ground that the penalty orders were illegal and not according to law
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1992 (9) TMI 1
Where an item unconnected with the escapement of income has been concluded finally, how far in reassessment on an escaped item of income is it open to the assessee to seek a review of the concluded item - HC clearly fell in error in permitting the assessee to reagitate, in the reassessment proceedings u/s 147(a), the finally concluded assessment proceedings and to grant to him relief in respect of items not only earlier rejected, but also unconnected with the escapement of income
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