INDORE MALWA UNITED MILLS vs COMMISSIONER OF INCOME-TAX, (CENTRAL) BOMBAY

The Supreme Court held that under Section 4(1)(a) of the Income-tax Act, 1922, the profits of a non-resident assessee are taxable in British India if received there. The Court ruled that the post office acted as the agent of the assessee for receiving cheques sent by the Government of India, thus establishing that the income was received in British India. The High Court's decision was upheld, allowing the Revenue authorities to argue this point for the first time.