https://www.taxtmi.com/caselaws?id=160580 A trading State was treated, for income-tax purposes, like a company, so interest on loans and connected receipts could be assessed where the statute created a real territorial nexus with British India. Commission under the Tata financing arrangement was held to arise from the Durbar's money-lending business, and dividends on shares and debentures taken in satisfaction of business debts were also treated as business income. Income from properties bought at execution sales was not assessable without a finding that the assets retained their trading character, so that point failed. Refund or set-off for deemed tax on dividends was denied because the statutory refund provisions did not extend to the State in its sovereign capacity. A dissent would have struck down the foreign-interest taxing clause as ultra vires. en-us Wed, 24 Nov 1948 00:00:00 +0530 Fri, 20 Dec 2013 18:06:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=160580 A trading State was treated, for income-tax purposes, like a company, so interest on loans and connected receipts could be assessed where the statute created a real territorial nexus with British India. Commission under the Tata financing arrangement was held to arise from the Durbar's money-lending business, and dividends on shares and debentures taken in satisfaction of business debts were also treated as business income. Income from properties bought at execution sales was not assessable without a finding that the assets retained their trading character, so that point failed. Refund or set-off for deemed tax on dividends was denied because the statutory refund provisions did not extend to the State in its sovereign capacity. A dissent would have struck down the foreign-interest taxing clause as ultra vires. Case-Laws Income Tax Wed, 24 Nov 1948 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=160580