https://www.taxtmi.com/caselaws?id=174126 Questions of place of assessment must be raised during assessment proceedings and determined by the Commissioner under the statutory procedure; a taxpayer cannot first raise a jurisdictional objection by requiring the Commissioner to state a case under the reference provision. Payments labelled as interest to partners that are in substance allocations of firm profits constitute income accruing personally to the partner and are taxable in the partner's hands (including as income from other sources) regardless of the firm's internal profit computation. The Section 14(2)(b) exemption applies only where the firm's profits have been actually assessed to income-tax, which was not the case here. en-us Wed, 25 Mar 1936 00:00:00 +0530 Wed, 30 Sep 2015 15:28:13 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=174126 Questions of place of assessment must be raised during assessment proceedings and determined by the Commissioner under the statutory procedure; a taxpayer cannot first raise a jurisdictional objection by requiring the Commissioner to state a case under the reference provision. Payments labelled as interest to partners that are in substance allocations of firm profits constitute income accruing personally to the partner and are taxable in the partner's hands (including as income from other sources) regardless of the firm's internal profit computation. The Section 14(2)(b) exemption applies only where the firm's profits have been actually assessed to income-tax, which was not the case here. Case-Laws Income Tax Wed, 25 Mar 1936 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=174126