Dismissing the appeal of the Revenue the\u00a0 Tribunal held that\u00a0 the assessee had only allowed his name to be used in the transactions and was personally involved in the making of these deals. The income earned by the assessee was not an appreciation of his investment, but consideration for being part of the arrangement to earn profit from transactions involving lands. The income earned was towards his personal involvement and for time contributed. There was no transfer of capital asset by the assessee. The amounts were invested by SDP and 90 per cent. of the profits made on the two transactions was remitted to his account. SDP had disclosed the profits made from these two transactions in his return of income under the head \u201cBusiness income\u201d which had been accepted under section\u00a0143(3). Principles of uniformity demanded that the balance 10 per cent. also to be taxed as \u201cBusiness income\u201d in the hands of the assessee.(AY.2011-12)<\/p>\n","protected":false},"excerpt":{"rendered":"
S. 143(3) : Assessment-Business income-Capital gains-90 Per Cent. of profits from transactions disclosed and taxed as business income in hands of other person-Principle of uniformity-Assessee\u2019s share of 10 Per Cent also be taxed as business income [S. 28(i), 45] <\/p>\n","protected":false},"author":3,"featured_media":0,"comment_status":"open","ping_status":"open","sticky":false,"template":"","format":"standard","meta":{"_acf_changed":false,"jetpack_post_was_ever_published":false,"_jetpack_newsletter_access":"","_jetpack_dont_email_post_to_subs":false,"_jetpack_newsletter_tier_id":0,"_jetpack_memberships_contains_paywalled_content":false,"_jetpack_memberships_contains_paid_content":false,"footnotes":""},"categories":[21],"tags":[],"class_list":["post-36726","post","type-post","status-publish","format-standard","hentry","category-income-tax-act"],"acf":[],"jetpack_featured_media_url":"","jetpack_shortlink":"https:\/\/wp.me\/p9S2Rw-9ym","jetpack-related-posts":[],"jetpack_sharing_enabled":true,"_links":{"self":[{"href":"https:\/\/itatonline.org\/digest\/wp-json\/wp\/v2\/posts\/36726","targetHints":{"allow":["GET"]}}],"collection":[{"href":"https:\/\/itatonline.org\/digest\/wp-json\/wp\/v2\/posts"}],"about":[{"href":"https:\/\/itatonline.org\/digest\/wp-json\/wp\/v2\/types\/post"}],"author":[{"embeddable":true,"href":"https:\/\/itatonline.org\/digest\/wp-json\/wp\/v2\/users\/3"}],"replies":[{"embeddable":true,"href":"https:\/\/itatonline.org\/digest\/wp-json\/wp\/v2\/comments?post=36726"}],"version-history":[{"count":1,"href":"https:\/\/itatonline.org\/digest\/wp-json\/wp\/v2\/posts\/36726\/revisions"}],"predecessor-version":[{"id":36727,"href":"https:\/\/itatonline.org\/digest\/wp-json\/wp\/v2\/posts\/36726\/revisions\/36727"}],"wp:attachment":[{"href":"https:\/\/itatonline.org\/digest\/wp-json\/wp\/v2\/media?parent=36726"}],"wp:term":[{"taxonomy":"category","embeddable":true,"href":"https:\/\/itatonline.org\/digest\/wp-json\/wp\/v2\/categories?post=36726"},{"taxonomy":"post_tag","embeddable":true,"href":"https:\/\/itatonline.org\/digest\/wp-json\/wp\/v2\/tags?post=36726"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}