https://www.taxtmi.com/caselaws?id=175482 A statutory apportionment formula requiring Indian branch profits to be matched against the company's total profits applies the term "profits" uniformly throughout the rule. The Court held that, for this computation, profits are taken before deduction of local income-tax and excess profits tax, because Indian assessable profits are themselves calculated without deducting Indian income-tax. Allowing deduction of foreign taxes from total profits would distort the comparison built into the formula and defeat its scheme. Commercial accounting authorities on tax as an outgoing were distinguished as inapplicable to taxable-income computation. The claimed deductions were therefore not allowable. en-us Mon, 14 Feb 1921 00:00:00 +0530 Mon, 23 Nov 2015 18:22:10 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=175482 A statutory apportionment formula requiring Indian branch profits to be matched against the company's total profits applies the term "profits" uniformly throughout the rule. The Court held that, for this computation, profits are taken before deduction of local income-tax and excess profits tax, because Indian assessable profits are themselves calculated without deducting Indian income-tax. Allowing deduction of foreign taxes from total profits would distort the comparison built into the formula and defeat its scheme. Commercial accounting authorities on tax as an outgoing were distinguished as inapplicable to taxable-income computation. The claimed deductions were therefore not allowable. Case-Laws Income Tax Mon, 14 Feb 1921 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=175482