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    <description>Commission under an indivisible managing agency agreement accrued in British India where the business was carried on, the managing agents performed their functions, and the amount was credited in the accounts. The fact that part of the consolidated profits related to branch business in the Indian States did not change the source or place of accrual of the commission. On those facts, the commission was held taxable as income accruing in British India, and the claim to exemption failed.</description>
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