All assessees are liable to tax in respect of the income received or deemed to be received by them in India during the previous year irrespective of –
(i) their residential status, and
(ii) the place of its accrual.
- Income is to be included in the total income of the assessee immediately on its actual or deemed receipt.
- The receipt of income refers to only the first occasion when the recipient gets the money under his control.
- Therefore, when once an amount is received as income, remittance or transmission of that amount from one place or person to another does not constitute receipt of income in the hands of the subsequent recipient or at the place of subsequent receipt.