https://www.taxtmi.com/caselaws?id=276744 Where the reference question was broad enough and the supporting facts were already on record, the Revenue was permitted to rely on a ground not earlier urged before the tax authorities or Tribunal. The majority also held that, when the creditor requests payment by cheque and the surrounding terms show posting as the authorised mode of transmission, the post office acts as the creditor's agent and receipt occurs where the cheque is posted. On the facts, the Government cheques posted from New Delhi were treated as receipt in the taxable territories, so the receipts were taxable there. en-us Sat, 12 Sep 1959 00:00:00 +0530 Fri, 16 Nov 2018 16:15:02 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=276744 Where the reference question was broad enough and the supporting facts were already on record, the Revenue was permitted to rely on a ground not earlier urged before the tax authorities or Tribunal. The majority also held that, when the creditor requests payment by cheque and the surrounding terms show posting as the authorised mode of transmission, the post office acts as the creditor's agent and receipt occurs where the cheque is posted. On the facts, the Government cheques posted from New Delhi were treated as receipt in the taxable territories, so the receipts were taxable there. Case-Laws Income Tax Sat, 12 Sep 1959 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=276744