https://www.taxtmi.com/caselaws?id=183568 Section 42(1) of the Income-tax Act, 1922 was treated as wide enough to cover a business connection where there was continuity of dealings between a non-resident and persons in British India, even without a formal agency. On the stated facts, repeated and substantial cloth purchases through named suppliers established such a connection. The text further notes that profit could be attributed to procurement in British India where no further intermediary operation was needed to earn it, and that apportionment under section 42(3) must rest on a rational basis; an attribution of 20% to purchase operations was considered reasonable in the circumstances of scarcity of cloth. en-us Sat, 07 Mar 1964 00:00:00 +0530 Tue, 14 Jun 2016 16:35:26 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=183568 Section 42(1) of the Income-tax Act, 1922 was treated as wide enough to cover a business connection where there was continuity of dealings between a non-resident and persons in British India, even without a formal agency. On the stated facts, repeated and substantial cloth purchases through named suppliers established such a connection. The text further notes that profit could be attributed to procurement in British India where no further intermediary operation was needed to earn it, and that apportionment under section 42(3) must rest on a rational basis; an attribution of 20% to purchase operations was considered reasonable in the circumstances of scarcity of cloth. Case-Laws Income Tax Sat, 07 Mar 1964 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=183568