https://www.taxtmi.com/caselaws?id=5311 In mixed-fund remittances from native States to British India, attribution to previously taxed profits is not automatic. The taxpayer may, in appropriate cases, treat payments as coming from taxed monies, but only where that attribution fits the facts and the statutory scheme. Here, because there was a single fund containing both taxed and untaxed profits, the Tribunal's apportionment method was accepted: one-third of each remittance was excluded to reflect profits already taxed under section 42(3), and the balance was brought to tax under section 14(2)(c). The claim that the entire remittance should be treated as taxed income was rejected. en-us Tue, 23 Oct 1990 00:00:00 +0530 Tue, 07 Jun 2016 14:26:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=5311 In mixed-fund remittances from native States to British India, attribution to previously taxed profits is not automatic. The taxpayer may, in appropriate cases, treat payments as coming from taxed monies, but only where that attribution fits the facts and the statutory scheme. Here, because there was a single fund containing both taxed and untaxed profits, the Tribunal's apportionment method was accepted: one-third of each remittance was excluded to reflect profits already taxed under section 42(3), and the balance was brought to tax under section 14(2)(c). The claim that the entire remittance should be treated as taxed income was rejected. Case-Laws Income Tax Tue, 23 Oct 1990 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=5311