https://www.taxtmi.com/caselaws?id=277479 Film-hire receipts under both fixed-hire and percentage-of-collections contracts were held to accrue wholly in the Native States because the assessee acquired an enforceable right to payment only when the films were delivered and exhibited there, or when collections were made there; the place where the contracts were made in British India was not decisive. The receipts were therefore exempt from excess profits tax under the third proviso to Section 5. The further contention that profits should be apportioned between British India and the Native States was not entertainable on reference because it had not been raised before the tax authorities or the Tribunal and did not arise from the Tribunal's order. en-us Fri, 21 Sep 1951 00:00:00 +0530 Wed, 05 Dec 2018 12:53:19 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=277479 Film-hire receipts under both fixed-hire and percentage-of-collections contracts were held to accrue wholly in the Native States because the assessee acquired an enforceable right to payment only when the films were delivered and exhibited there, or when collections were made there; the place where the contracts were made in British India was not decisive. The receipts were therefore exempt from excess profits tax under the third proviso to Section 5. The further contention that profits should be apportioned between British India and the Native States was not entertainable on reference because it had not been raised before the tax authorities or the Tribunal and did not arise from the Tribunal's order. Case-Laws Income Tax Fri, 21 Sep 1951 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=277479