It is a basic principle of the Income Tax Acts1 that, so far as possible, tax should be collected at the source of the income2. Accordingly, in many instances those Acts render a person assessable or accountable to the Crown in respect of income tax on income which, although it arises from a source within his control or passes through his hands, is income that belongs in fact to another. Where this is so, the person so assessable or accountable has in general a right or a duty, on making a payment of that income to the person entitled
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