Accrual, arises and receipt

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..... he United Kingdom 'as' coming into the person's hands in the United Kingdom. In CIT, Bombay v. Ahmedbhai Umarbhai & Co.- 1950 (5) TMI 1 - SUPREME COURT, Bombay where it was observed :--- "Whether the words 'derive' and 'produce' are or are not synonymous with the words 'accrue' or 'arise', it can be said without hesitation that the words 'a .....

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..... he accrual of profits and their apportionment inter se..................." The Honorable Supreme Court in the case of E.D. Sassoon & Co. Ltd. v CIT - 1954 (5) TMI 2 - SUPREME COURT, discussed the concepts of 'accrual', 'arises' and 'receipt'. The relevant observations are as under: "'Accrues', 'arises' and 'is received' are three distinct terms. So far as receiving .....

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..... age; while the word 'arises' means comes into existence or notice or presents itself. The former connotes the idea of a growth or accumulation and the latter of the growth or accumulation with a tangible shape so as to be receivable. It is difficult to say that this distinction has been throughout maintained in the Act and perhaps the two words seem to denote the same idea or ideas very si .....

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..... d "accrue" is "to come as an accession, increment, or produce: to fall to one by way of advantage: to fall due ". The income can thus be said to accrue when it becomes due. The postponement of the date of payment has a bearing only in so far as the time of payment is concerned, but it does not affect the accrual of income. The moment the income accrues, the assessee gets vested .....

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..... ub-section." The Honorable Supreme Court in the case in CIT v Excel Industries Limited - 2013 (10) TMI 324 - SUPREME COURT, after considering decision in the case of Movi Industries ltd (supra) has observed that: "19. This Court further held, and in our opinion more importantly, that income accrues when there "arises a corresponding liability of the other party from whom the income be .....

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