https://www.taxtmi.com/caselaws?id=58388 Royalty payable to a non-resident accrued in India when it became due under the agreement during the accounting year and had to be computed quarterly on sales, so it was taxable on accrual basis under section 5(2)(b) of the Income-tax Act, 1961. The assessee's overseas accounts showing receipt basis did not control Indian tax chargeability, section 145 did not assist in the absence of Indian books for the relevant source, and delay or refusal in seeking remittance permission did not defer accrual. Section 115A governed only the tax rate, not the year of taxability, and section 205 afforded no relief because no tax had been deducted at source. en-us Fri, 08 Apr 1988 00:00:00 +0530 Sat, 18 Dec 2010 17:22:24 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=58388 Royalty payable to a non-resident accrued in India when it became due under the agreement during the accounting year and had to be computed quarterly on sales, so it was taxable on accrual basis under section 5(2)(b) of the Income-tax Act, 1961. The assessee's overseas accounts showing receipt basis did not control Indian tax chargeability, section 145 did not assist in the absence of Indian books for the relevant source, and delay or refusal in seeking remittance permission did not defer accrual. Section 115A governed only the tax rate, not the year of taxability, and section 205 afforded no relief because no tax had been deducted at source. Case-Laws Income Tax Fri, 08 Apr 1988 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=58388