https://www.taxtmi.com/caselaws?id=6491 Royalties received in England under a broadcasting agreement were held to accrue or arise in India because the real source of the receipts was the broadcast of copyright music from stations in India, making them taxable under the Income-tax Act. The place of payment and execution of the contract was treated as irrelevant, and there was no need to rely on the deeming rule in section 9(1)(i). The society's obligation to distribute the royalties to members was only a post-receipt application of income, not a diversion by overriding title, because the amounts first became the society's own receipts. The appeal therefore failed. en-us Tue, 10 Aug 1976 00:00:00 +0530 Fri, 05 Dec 2008 00:00:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=6491 Royalties received in England under a broadcasting agreement were held to accrue or arise in India because the real source of the receipts was the broadcast of copyright music from stations in India, making them taxable under the Income-tax Act. The place of payment and execution of the contract was treated as irrelevant, and there was no need to rely on the deeming rule in section 9(1)(i). The society's obligation to distribute the royalties to members was only a post-receipt application of income, not a diversion by overriding title, because the amounts first became the society's own receipts. The appeal therefore failed. Case-Laws Income Tax Tue, 10 Aug 1976 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=6491