https://www.taxtmi.com/caselaws?id=49693 The SC distinguished between the right to receive income and the right to ownership of income in a managing agency commission case. When a managing agency was assigned mid-year, the court held that the year's commission constituted joint income of both assignor and assignee based on their respective periods of service. Although the assignee had the right to collect the entire commission under the assignment arrangement, the assignor's proportionate share remained their taxable income. The court rejected arguments that the managing agency was income-bearing property that transferred completely upon assignment, emphasizing that assignment clauses operate prospectively, not retrospectively. The HC decision was upheld, confirming the assignor remained liable for tax on their share of the commission. en-us Fri, 14 May 1954 00:00:00 +0530 Thu, 03 Jul 2025 16:59:29 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=49693 The SC distinguished between the right to receive income and the right to ownership of income in a managing agency commission case. When a managing agency was assigned mid-year, the court held that the year's commission constituted joint income of both assignor and assignee based on their respective periods of service. Although the assignee had the right to collect the entire commission under the assignment arrangement, the assignor's proportionate share remained their taxable income. The court rejected arguments that the managing agency was income-bearing property that transferred completely upon assignment, emphasizing that assignment clauses operate prospectively, not retrospectively. The HC decision was upheld, confirming the assignor remained liable for tax on their share of the commission. Case-Laws Income Tax Fri, 14 May 1954 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=49693