https://www.taxtmi.com/caselaws?id=290080 Commission attributable to supervision, control and general advice rendered from London did not accrue or arise in India merely because the underlying goods were sold in India. The selling function had been transferred to another agent, so the commission was not earned through sales operations carried out in India. On those facts, Section 4(1) of the Indian Income Tax Act did not apply; if taxability was otherwise attracted, the matter would fall under Section 42(3). The reference was answered in favour of the assessee. en-us Mon, 15 Jan 1951 00:00:00 +0530 Tue, 08 Sep 2020 14:06:16 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=290080 Commission attributable to supervision, control and general advice rendered from London did not accrue or arise in India merely because the underlying goods were sold in India. The selling function had been transferred to another agent, so the commission was not earned through sales operations carried out in India. On those facts, Section 4(1) of the Indian Income Tax Act did not apply; if taxability was otherwise attracted, the matter would fall under Section 42(3). The reference was answered in favour of the assessee. Case-Laws Income Tax Mon, 15 Jan 1951 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=290080