https://www.taxtmi.com/caselaws?id=173232 A statutory residence test for companies was upheld where it treated a company as resident because its British Indian income exceeded its foreign income and then included foreign income in total income. The provision was treated as a machinery rule with a sufficient territorial nexus, not as an invalid extra-territorial law, because it did not directly regulate conduct or property outside the territory. On territorial assessment, the company's business connection in Bombay supported assessment by the Bombay Income-tax Officer, and the argument that it was only a sleeping partner did not alter that position. en-us Mon, 15 Jan 1945 00:00:00 +0630 Thu, 10 Sep 2015 13:05:26 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=173232 A statutory residence test for companies was upheld where it treated a company as resident because its British Indian income exceeded its foreign income and then included foreign income in total income. The provision was treated as a machinery rule with a sufficient territorial nexus, not as an invalid extra-territorial law, because it did not directly regulate conduct or property outside the territory. On territorial assessment, the company's business connection in Bombay supported assessment by the Bombay Income-tax Officer, and the argument that it was only a sleeping partner did not alter that position. Case-Laws Income Tax Mon, 15 Jan 1945 00:00:00 +0630 https://www.taxtmi.com/caselaws?id=173232