https://www.taxtmi.com/caselaws?id=21976 Rule 115(c) of the Income-tax Rules was examined for whether foreign exchange export receipts had to be converted at the rate prevailing on the last day of the previous year, rather than on the date of actual receipt. The Court held that income tax attaches to income when actually received in the course of business, and that delegated rules under section 295 cannot widen the charging provisions or impose tax on notional income not yet received or realisable. On that basis, rule 115(c), as then framed, was beyond the parent Act and could not be applied to the assessee's export receipts; the revisional order was quashed. en-us Wed, 04 Mar 1992 00:00:00 +0530 Sat, 05 Dec 2009 12:16:04 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=21976 Rule 115(c) of the Income-tax Rules was examined for whether foreign exchange export receipts had to be converted at the rate prevailing on the last day of the previous year, rather than on the date of actual receipt. The Court held that income tax attaches to income when actually received in the course of business, and that delegated rules under section 295 cannot widen the charging provisions or impose tax on notional income not yet received or realisable. On that basis, rule 115(c), as then framed, was beyond the parent Act and could not be applied to the assessee's export receipts; the revisional order was quashed. Case-Laws Income Tax Wed, 04 Mar 1992 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=21976