1931 (7) TMI 20

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....the Eight Revd. C.J.G. Sounders, Lord Bishop of Lucknow. 2. The facts of the case are very short and simple. The Lord Bishop of Lucknow draws a salary from the Government of India. He also receives an amount of money ranging from GBP600 to GBP700 a year, which is payable to him and which is paid to him in London. This income arises in this way. Certain subscriptions were raised both in India an....

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....o make the present reference. 4. The Commissioner of Income Tax has framed three questions, and they are as follows: (1) Whether the sums received from the Colonial Bishopric Fund were income of the assessee within the meaning of Section 3, Indian Income Tax Act, (2) Whether this income arose in British India. (3) Whether the tax on this income was payable under the h....

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.... any " fees and perquisites received by the assessee in lieu of, or in addition to, any salary or wages, or on behalf of any public body. The word "perquisites" is a very wide word, and its meaning as given in Murray's English Dictionary, is as follows: Any casual emolument, fee or profit attached to an office or position, in addition to salary or wages. 7. In stating the facts, we....

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....nd the same meaning. They must have been used in denoting different ideas. There can be no doubt that the allowance was not "received" in British India. The question is, did it "accrue" or arise in British India. In our opinion, it did. The reason is very simple, and it is this. If the assessee chooses to give up his appointment as Lord Bishop of Lucknow, and he further chooses to go back to Engla....