https://www.taxtmi.com/caselaws?id=276982 For section 4(1)(a) of the Income-tax Act, 1922, the first receipt of income by or on behalf of a foreign principal is the material test. Where a statutory agent remits sale money before actually realising the proceeds from purchasers, the payment is made in discharge of an independent contractual obligation and is not a receipt of the sale proceeds by the principal in the taxable territories. If the agent remits only after the proceeds have been realised, the remittance is merely a transfer of money already received on the principal's behalf, and receipt basis taxation applies. en-us Thu, 24 Feb 1955 00:00:00 +0530 Wed, 21 Nov 2018 16:55:04 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=276982 For section 4(1)(a) of the Income-tax Act, 1922, the first receipt of income by or on behalf of a foreign principal is the material test. Where a statutory agent remits sale money before actually realising the proceeds from purchasers, the payment is made in discharge of an independent contractual obligation and is not a receipt of the sale proceeds by the principal in the taxable territories. If the agent remits only after the proceeds have been realised, the remittance is merely a transfer of money already received on the principal's behalf, and receipt basis taxation applies. Case-Laws Income Tax Thu, 24 Feb 1955 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=276982