E. D. SASSOON AND COMPANY LTD. vs THE COMMISSIONER OF INCOME-TAX,BOMBAY CITY.(With connected

The Supreme Court held that under Section 4(1)(a) of the Indian Income-tax Act, the Managing Agency commission is indivisible and becomes due only upon the completion of a definite period of service. The Court ruled that the Sassoons had not earned any income for broken periods and thus no commission was payable for those periods. Consequently, the income transferred to the transferees did not include any accrued income during the chargeable accounting period, leading to the conclusion that no income had accrued to the Sassoons for tax purposes.