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PETITIONER: E. D. SASSOON AND COMPANY LTD.
Vs.
RESPONDENT: THE COMMISSIONER OF INCOME-TAX,BOMBAY CITY.(With connected A
DATE OF JUDGMENT: 14/05/1954
BENCH: BHAGWATI, NATWARLAL H. BENCH: BHAGWATI, NATWARLAL H. DAS, SUDHI RANJAN JAGANNADHADAS, B.
CITATION: 1954 AIR 470 1955 SCR 599 CITATOR INFO : D 1960 SC 703 (3,5) R 1960 SC1279 (2,8) D 1961 SC1007 (12) R 1964 SC1653 (7) F 1965 SC1343 (6,8,9,11,12) R 1967 SC1626 (5) F 1977 SC 560 (7) R 1986 SC1805 (5) RF 1991 SC 513 (7) RF 1992 SC1495 (17)
ACT: Indian Income-tax Act (XI of 1922) s. 4(1)(a)(b)-"Income," accrues arises’ is received"-Meaning of-"Earned"-Meaning of- s. 10(1)-"Carried on by him"-Connotation of-Managing Agency Agreement-Transfer of rights thereunder-Apportionment between assignors and assignees.
HEADNOTE: The Sassoons had entered into three Managing Agency agree- ments as the Managing Agents of three different companies. They transferred their Managing Agencies to three other companies by formal deeds of assignment and transfer on several dates during the accounting year. The question for determination was whether in the circum. stances of the case the Managing Agency commission was liable to be apportioned between the Sassoons and their respective transferees in the proportion of...