SHOORJI VALLABHDAS & CO., BOMBAY vs THE COMMISSIONER OF INCOME-TAX/EXCESSPROFITS TAX, BOMBAY.

The Supreme Court held that the managing agency commission accrued at the place where the services were performed, which in this case was Bombay, as most of the managing work was conducted there. The Court ruled that the entire commission was taxable in British India under Section 14(2)(C) of the Indian Income-tax Act, 1922, and the third proviso to Section 5 of the Excess Profits Tax Act, 1940. The appeal was dismissed, affirming the tax liability on the full commission received by the appellant.