https://www.taxtmi.com/caselaws?id=25992 Managing agency commission was treated as accruing where the managing agent actually carried on the substantive business of managing the managed concern, not merely where the head office was located or where remuneration was computed. On the stated facts, the managed company's factory, manufacturing operations and sales were in Pakistan, so the commission-generating activities arose there. The presence of the assessee's head office in India did not, by itself, fix accrual in India, and the double taxation arrangement supported that territorial sourcing analysis. On that reasoning, inclusion of half the commission in the Indian assessment was not justified. en-us Tue, 17 Dec 1974 00:00:00 +0530 Tue, 02 Feb 2010 11:35:12 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=25992 Managing agency commission was treated as accruing where the managing agent actually carried on the substantive business of managing the managed concern, not merely where the head office was located or where remuneration was computed. On the stated facts, the managed company's factory, manufacturing operations and sales were in Pakistan, so the commission-generating activities arose there. The presence of the assessee's head office in India did not, by itself, fix accrual in India, and the double taxation arrangement supported that territorial sourcing analysis. On that reasoning, inclusion of half the commission in the Indian assessment was not justified. Case-Laws Income Tax Tue, 17 Dec 1974 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=25992