https://www.taxtmi.com/caselaws?id=7005 A remittance through book entries can constitute a transfer of foreign income to India even without physical movement of cash, because a credit entry may give the assessee control over the amount. The timing of the credit is material: where the relevant credit falls outside the accounting year, it cannot support inclusion of the sum in that year's taxable foreign income. Where both taxed and untaxed foreign funds exist and the source of remittance is not identified, the remittance is presumed to come from the taxed fund, and that presumption must be rebutted by the revenue before denying the statutory allowance under the third proviso to Section 4(1) of the Income-tax Act, 1922. en-us Mon, 09 Jan 1967 00:00:00 +0530 Sat, 07 Feb 2009 19:07:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=7005 A remittance through book entries can constitute a transfer of foreign income to India even without physical movement of cash, because a credit entry may give the assessee control over the amount. The timing of the credit is material: where the relevant credit falls outside the accounting year, it cannot support inclusion of the sum in that year's taxable foreign income. Where both taxed and untaxed foreign funds exist and the source of remittance is not identified, the remittance is presumed to come from the taxed fund, and that presumption must be rebutted by the revenue before denying the statutory allowance under the third proviso to Section 4(1) of the Income-tax Act, 1922. Case-Laws Income Tax Mon, 09 Jan 1967 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=7005