https://www.taxtmi.com/caselaws?id=178189 Income-tax treatment of inter-branch transactions depends on the real substance of the transaction and the place of actual receipt, rather than internal book entries. A balance recorded between branches of the same assessee cannot be treated as income brought into British India without evidence of actual remittance; no presumption of receipt arises merely from a branch account balance. Likewise, an invoiced margin on goods transferred between branches cannot create profit earned outside British India, because the branches are not separate legal persons. Taxability instead attaches to the real profit from sales in British India as income received there, rather than as income brought into the territory. en-us Wed, 07 Mar 1945 00:00:00 +0630 Fri, 29 Jan 2016 16:40:07 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=178189 Income-tax treatment of inter-branch transactions depends on the real substance of the transaction and the place of actual receipt, rather than internal book entries. A balance recorded between branches of the same assessee cannot be treated as income brought into British India without evidence of actual remittance; no presumption of receipt arises merely from a branch account balance. Likewise, an invoiced margin on goods transferred between branches cannot create profit earned outside British India, because the branches are not separate legal persons. Taxability instead attaches to the real profit from sales in British India as income received there, rather than as income brought into the territory. Case-Laws Income Tax Wed, 07 Mar 1945 00:00:00 +0630 https://www.taxtmi.com/caselaws?id=178189