SHRI JAGDISH MILLS LTD. vs THE COMMISSIONER OF INCOME-TAX, BOMBAY NORTH, KUTCH A

The Supreme Court held that under Section 4(1)(a) of the Indian Income-tax Act, 1922, the amounts received by the appellant company via cheques sent by post constituted income received in taxable territories. The Court found that there was an implied request for the cheques to be sent by post, establishing the Post Office as the agent for receiving payments. The decision followed the precedent set in Commissioner of Income-tax, Bombay South v. Messrs. Ogale Glass Works Ltd. [1955] I S.C.R. 185, affirming the liability of the appellant to pay tax on the received amounts.