https://www.taxtmi.com/caselaws?id=172295 Profits from timber contracts were analysed by reference to where the transaction substantively came into existence and where the right to payment arose, not merely where the offers were accepted. Because the timber was manufactured, inspected, appropriated, delivered, and paid for in Cochin State, the profits were held to have accrued or arisen outside British India, leaving no charge on that basis. The discussion also clarified that Section 42(3) operates only as a deeming rule for profits treated by statute as accruing or arising in British India, and does not extend to profits that in fact accrued there. The revenue's contention was rejected and costs were awarded to the assessee. en-us Fri, 18 Nov 1949 00:00:00 +0530 Tue, 18 Aug 2015 17:29:10 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=172295 Profits from timber contracts were analysed by reference to where the transaction substantively came into existence and where the right to payment arose, not merely where the offers were accepted. Because the timber was manufactured, inspected, appropriated, delivered, and paid for in Cochin State, the profits were held to have accrued or arisen outside British India, leaving no charge on that basis. The discussion also clarified that Section 42(3) operates only as a deeming rule for profits treated by statute as accruing or arising in British India, and does not extend to profits that in fact accrued there. The revenue's contention was rejected and costs were awarded to the assessee. Case-Laws Income Tax Fri, 18 Nov 1949 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=172295