Except in the case of trading profits charged on an earnings basis1 and income from company distributions2, the general rule is that a sum due to a person is not his income so as to be liable to assessment to tax unless and until it is received by him or on his behalf3. Thus, where default is made in payment of interest payable under deduction of tax, that interest does not form part of the total income of the person entitled to it so long as it is in arrears and unpaid4. It has been held that where a
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