Supreme Court Decision Expands "Attributable To" Scope Over "Derived From" in Tax Cases; Instruction No. 596 Inoperative.

The circular addresses the applicability of the Supreme Court's decision in the case involving Cambay Electric Supply Industrial Co. and the Commissioner of Income Tax, Gujarat. The court ruled that the term "attributable to" has a broader scope than "derived from," rendering Instruction No. 596 dated August 24, 1973, inoperative. Consequently, similar cases should be resolved based on this Supreme Court judgment.

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