https://www.taxtmi.com/caselaws?id=176458 Income actually collected in British India on Cawnpore sales was treated as received there and therefore taxable under the charging provisions without apportionment between manufacture outside and sale within British India. The court also stated that the expression "profits and gains" referred to the ordinary commercial profit on sale. By contrast, sales to British India customers through independent brokers did not create a deemed accrual in British India, because the assessee had no branch, agency, or other establishment there and the brokers were not retained agents. The deeming rule was said to require a real, substantive business connection with a business in British India. en-us Wed, 03 Jan 1945 00:00:00 +0630 Wed, 23 Dec 2015 13:28:28 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=176458 Income actually collected in British India on Cawnpore sales was treated as received there and therefore taxable under the charging provisions without apportionment between manufacture outside and sale within British India. The court also stated that the expression "profits and gains" referred to the ordinary commercial profit on sale. By contrast, sales to British India customers through independent brokers did not create a deemed accrual in British India, because the assessee had no branch, agency, or other establishment there and the brokers were not retained agents. The deeming rule was said to require a real, substantive business connection with a business in British India. Case-Laws Income Tax Wed, 03 Jan 1945 00:00:00 +0630 https://www.taxtmi.com/caselaws?id=176458