https://www.taxtmi.com/caselaws?id=175840 Where a contract was negotiated and concluded in British India as an essential trading operation connected with the earning of profits, section 42(1) of the Indian Income-tax Act, 1922 applied even though the profits were realised in Cochin State. The profits therefore required apportionment under section 42(3) on a rational basis. The Madras HC held that the Tribunal's flat 50 per cent attribution to the British India operation was unsupported and arbitrary on the facts, because the relevant activity in British India was limited to negotiation and conclusion of the contract. Only ten per cent of the assessee's share of profits was attributable to that operation. en-us Wed, 24 Feb 1960 00:00:00 +0530 Mon, 07 Dec 2015 10:43:11 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=175840 Where a contract was negotiated and concluded in British India as an essential trading operation connected with the earning of profits, section 42(1) of the Indian Income-tax Act, 1922 applied even though the profits were realised in Cochin State. The profits therefore required apportionment under section 42(3) on a rational basis. The Madras HC held that the Tribunal's flat 50 per cent attribution to the British India operation was unsupported and arbitrary on the facts, because the relevant activity in British India was limited to negotiation and conclusion of the contract. Only ten per cent of the assessee's share of profits was attributable to that operation. Case-Laws Income Tax Wed, 24 Feb 1960 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=175840