https://www.taxtmi.com/caselaws?id=39978 Amounts received under the trust were held to be realised in India, because the trust deed and tripartite agreement required payment in India and the trustees remitted the sums to London only as the assessees' agents. The finding that the remittance arrangement reflected agency, and was supported by evidence, was treated as a factual conclusion not shown to be perverse. On that basis, the receipts did not qualify as amounts realised outside India, and exemption under section 5(o)(ii) of the Expenditure-tax Act, 1957 was unavailable. en-us Fri, 09 Mar 1973 00:00:00 +0530 Wed, 06 Aug 2014 17:26:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=39978 Amounts received under the trust were held to be realised in India, because the trust deed and tripartite agreement required payment in India and the trustees remitted the sums to London only as the assessees' agents. The finding that the remittance arrangement reflected agency, and was supported by evidence, was treated as a factual conclusion not shown to be perverse. On that basis, the receipts did not qualify as amounts realised outside India, and exemption under section 5(o)(ii) of the Expenditure-tax Act, 1957 was unavailable. Case-Laws Indian Laws Fri, 09 Mar 1973 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=39978