https://www.taxtmi.com/caselaws?id=183220 Under the Income-tax Act, 1922, the decisive test for taxing profits was where the profits came into existence, not merely where decisions were taken or business control was exercised. The statutory scheme in sections 4, 6 and 10 required a direct enquiry into whether particular profits accrued or arose in British India, and did not make the place of direction the sole criterion. Because the future delivery contracts were neither framed nor carried out in British India, the profits from those foreign dealings did not accrue or arise there, and the issue was resolved in favour of the assessee. en-us Thu, 16 Jun 1938 00:00:00 +0530 Wed, 01 Jun 2016 18:30:11 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=183220 Under the Income-tax Act, 1922, the decisive test for taxing profits was where the profits came into existence, not merely where decisions were taken or business control was exercised. The statutory scheme in sections 4, 6 and 10 required a direct enquiry into whether particular profits accrued or arose in British India, and did not make the place of direction the sole criterion. Because the future delivery contracts were neither framed nor carried out in British India, the profits from those foreign dealings did not accrue or arise there, and the issue was resolved in favour of the assessee. Case-Laws Income Tax Thu, 16 Jun 1938 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=183220