<?xml version="1.0" encoding="UTF-8"?>
<?xml-stylesheet type="text/xsl" href="https://www.taxtmi.com/rss_sitemap/rss_feed_blog.xsl?v=1750492856"?>
<rss version="2.0" xmlns:atom="http://www.w3.org/2005/Atom">
  <channel>
    <title>1954 (5) TMI 2 - Supreme Court</title>
    <link>https://www.taxtmi.com/caselaws?id=49693</link>
    <description>Income accrues only when the assessee acquires a vested contractual right to receive it; under an entire managing agency contract with annual remuneration, no commission for a broken period accrues before the year is completed and the contractual conditions precedent are satisfied. The managing agency commission for the broken period was therefore not taxable in the transferor&#039;s hands. Section 36 of the Transfer of Property Act, 1882 did not create apportionment contrary to the contract, and section 26(2) of the Indian Income-tax Act, 1922 did not apply because the transferor had not acquired any part of the income before assignment. The transferees were taxable on the whole commission received.</description>
    <language>en-us</language>
    <pubDate>Fri, 14 May 1954 00:00:00 +0530</pubDate>
    <lastBuildDate>Thu, 03 Jul 2025 16:59:29 +0530</lastBuildDate>
    <generator>TaxTMI RSS Generator</generator>
    <atom:link href="https://www.taxtmi.com/rss_feed_blog?id=88173" rel="self" type="application/rss+xml"/>
    <item>
      <title>1954 (5) TMI 2 - Supreme Court</title>
      <link>https://www.taxtmi.com/caselaws?id=49693</link>
      <description>Income accrues only when the assessee acquires a vested contractual right to receive it; under an entire managing agency contract with annual remuneration, no commission for a broken period accrues before the year is completed and the contractual conditions precedent are satisfied. The managing agency commission for the broken period was therefore not taxable in the transferor&#039;s hands. Section 36 of the Transfer of Property Act, 1882 did not create apportionment contrary to the contract, and section 26(2) of the Indian Income-tax Act, 1922 did not apply because the transferor had not acquired any part of the income before assignment. The transferees were taxable on the whole commission received.</description>
      <category>Case-Laws</category>
      <law>Income Tax</law>
      <pubDate>Fri, 14 May 1954 00:00:00 +0530</pubDate>
      <guid isPermaLink="true">https://www.taxtmi.com/caselaws?id=49693</guid>
    </item>
  </channel>
</rss>