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Issues: Whether remittances of annuity instalments sent by an agent from Mysore Province to a resident in British India constituted income received in British India and were taxable under the Income-tax Act (II of 1886).
Analysis: The remittances were treated as income under Part IV of Schedule II of the Income-tax Act (II of 1886). The Court held that income means what comes in, and sums derived from such a source remain income even after collection by the agent. Since the amounts were sent to and received by the assessee in British India, they fell within the definition of receipt in section 3(5) of the Act and were liable to tax.
Conclusion: The remittances were taxable income received in British India; the appellant's contention was rejected.