https://www.taxtmi.com/caselaws?id=57972 Dividend on foreign shares received by non-resident assessees through a banking remittance arrangement was held first received in India because the Hongkong office acted only as a collection and onward-remittance channel, not as the assessees' substituted agent. The assessees had no direct authority or contractual privity with the Hongkong office, and the dividend remained beyond their control until the rupee equivalent was credited in India. The income was therefore taxable in India under section 5(2)(a) of the Income-tax Act, 1961; the substituted-agent contention failed. en-us Thu, 19 Mar 1987 00:00:00 +0530 Sun, 06 Feb 2011 03:32:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=57972 Dividend on foreign shares received by non-resident assessees through a banking remittance arrangement was held first received in India because the Hongkong office acted only as a collection and onward-remittance channel, not as the assessees' substituted agent. The assessees had no direct authority or contractual privity with the Hongkong office, and the dividend remained beyond their control until the rupee equivalent was credited in India. The income was therefore taxable in India under section 5(2)(a) of the Income-tax Act, 1961; the substituted-agent contention failed. Case-Laws Income Tax Thu, 19 Mar 1987 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=57972