https://www.taxtmi.com/caselaws?id=57972 The Tribunal dismissed the appeals, upholding the CIT's orders for both assessment years. It held that the income was taxable in India when the rupee equivalent was credited to the assessees' accounts, under section 5(2)(a) of the Income-tax Act. The Tribunal found no evidence of the Hongkong office acting as a substituted agent and deemed the arrangement a tax avoidance scheme. The assessees' resident status under FERA further supported the department's position. 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 The Tribunal dismissed the appeals, upholding the CIT's orders for both assessment years. It held that the income was taxable in India when the rupee equivalent was credited to the assessees' accounts, under section 5(2)(a) of the Income-tax Act. The Tribunal found no evidence of the Hongkong office acting as a substituted agent and deemed the arrangement a tax avoidance scheme. The assessees' resident status under FERA further supported the department's position. Case-Laws Income Tax Thu, 19 Mar 1987 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=57972