https://www.taxtmi.com/caselaws?id=169598 Dividend income was treated as accruing where the dividend came into existence by declaration and payment, and on the stated facts that place was Navsari in the former Baroda State rather than British India. The later merger of the State did not alter the factual place of accrual. The same income was nevertheless deemed to accrue in British India under section 42(1) because the shares were situated in Bombay, while the special dividend explanation to section 4(1) was confined to non-resident shareholders and did not protect a resident assessee. The result was that the income was factually accrued outside British India but statutorily deemed to accrue within it. en-us Mon, 18 Sep 1961 00:00:00 +0530 Mon, 27 Apr 2015 15:33:54 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=169598 Dividend income was treated as accruing where the dividend came into existence by declaration and payment, and on the stated facts that place was Navsari in the former Baroda State rather than British India. The later merger of the State did not alter the factual place of accrual. The same income was nevertheless deemed to accrue in British India under section 42(1) because the shares were situated in Bombay, while the special dividend explanation to section 4(1) was confined to non-resident shareholders and did not protect a resident assessee. The result was that the income was factually accrued outside British India but statutorily deemed to accrue within it. Case-Laws Income Tax Mon, 18 Sep 1961 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=169598