https://www.taxtmi.com/caselaws?id=185032 Managing agency commission was held to accrue where the right to receive it came into existence, not where parts of the work were performed. Because the commission was calculated on the company's net profits as a whole and became payable only after all operations were aggregated and accounts were submitted to the head office in Bombay, the local supervision and work at Kandla did not create separate accruals. The decisive legal test was the situs of the right to receive the commission. On that basis, the commission accrued and arose in British India, not in the State of Kutch, for income-tax and excess profits tax purposes. en-us Thu, 15 Sep 1949 00:00:00 +0530 Thu, 28 Jul 2016 16:27:01 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=185032 Managing agency commission was held to accrue where the right to receive it came into existence, not where parts of the work were performed. Because the commission was calculated on the company's net profits as a whole and became payable only after all operations were aggregated and accounts were submitted to the head office in Bombay, the local supervision and work at Kandla did not create separate accruals. The decisive legal test was the situs of the right to receive the commission. On that basis, the commission accrued and arose in British India, not in the State of Kutch, for income-tax and excess profits tax purposes. Case-Laws Income Tax Thu, 15 Sep 1949 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=185032