Whether income had accrued or arisen to the taxpayer?
Whether the right to receive the amount was vested in the taxpayer?
Income cannot be said to accrue or arise to an assessee unless there is a right to receive the amount, and the compensation for managing agencies did not constitute income that was taxable under the Income Tax Act.
Whether the various processes that the tobacco leaves underwent, transformed the nature of the income received from their sales into agricultural income or general business income?
Whether the said income, if agricultural falls under Section 2(1) of the Income Tax Act, 1922?
Basic Operations v. Subsequent Operations is the primary distinguisher that is applied in similar cases is the determining factor, in the sense that basic operations are those which are essential for the cultivation of land, and subsequent operations differ when acts are done to the produce after it is harvested to make it marketable. The basic relationship between agricultural produce and operations performed on land is of utmost importance.
The Principle of Agency Contracts governs the consent, fiduciary relationship, and binding effect on two or more parties to act on behalf of the other, processes such as terminations, ratifications, and remunerations are carried out using agency contracts.
Whether the assessee (Hindu Undivided Family) was a resident in British India under Section 4A(b) of the Income Tax Act, 1922?
The principle of determining the residential status of a Hindu Undivided Family (HUF) for tax purposes is based on the control and management of the family.
Section 4A(b) of the Income Tax Act, 1922 says that a Hindu Undivided Family, firm, or other association of persons resides in British India unless the control and management of its affairs is wholly outside British India.