THE COMMISSIONER OF INCOME-TAX, BOMBAY vs DHARAMDAS HARGOVINDAS.

The Supreme Court held that under Section 4(1)(b)(iii) of the Income-tax Act, 1922, a resident in taxable territories is liable to tax on income brought into the taxable territory, even if it was previously received outside. The court clarified that while the first receipt of income in the taxable territory must be the first receipt for clause (a), for clause (b)(iii), it need not be the first receipt. The appeal by the Commissioner of Income-tax was allowed, affirming the tax liability of the assessee on the amount transferred to Bombay.