https://www.taxtmi.com/caselaws?id=169735 Interest earned on remitted insurance funds was held taxable only to the extent reasonably attributable to operations carried on in British India, because the income arose from a composite cross-border business process that could be separated into Indian and non-Indian operations under section 42(1) and section 42(3). The fund remittance and investment abroad required apportionment, with relief for the portion attributable to operations outside British India. The appellate tribunal was also found unable to introduce rule 8 as a new and more onerous basis of computation when that issue had not been raised in the appeal, since its appellate power did not extend to enhancing the assessment in that manner. en-us Wed, 13 Sep 1944 00:00:00 +0630 Sat, 02 May 2015 11:27:01 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=169735 Interest earned on remitted insurance funds was held taxable only to the extent reasonably attributable to operations carried on in British India, because the income arose from a composite cross-border business process that could be separated into Indian and non-Indian operations under section 42(1) and section 42(3). The fund remittance and investment abroad required apportionment, with relief for the portion attributable to operations outside British India. The appellate tribunal was also found unable to introduce rule 8 as a new and more onerous basis of computation when that issue had not been raised in the appeal, since its appellate power did not extend to enhancing the assessment in that manner. Case-Laws Income Tax Wed, 13 Sep 1944 00:00:00 +0630 https://www.taxtmi.com/caselaws?id=169735