https://www.taxtmi.com/caselaws?id=6475 Where business profits are to be apportioned between taxable and non-taxable territories, the issue is factual and requires a just and equitable estimate in the absence of any statutory formula. The Tribunal found that the assessee had a business organisation in British India that promoted sales, that the groundwork for the transactions was done there, and that the contracts were completed on the record facts. Because the apportionment was based on relevant material and the circumstances of the case, it was not to be disturbed. The profit treated as accruing or arising in British India was accordingly upheld at Rs. 54,400 for the assessment year 1942-43. en-us Fri, 19 Mar 1976 00:00:00 +0530 Fri, 05 Dec 2008 00:00:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=6475 Where business profits are to be apportioned between taxable and non-taxable territories, the issue is factual and requires a just and equitable estimate in the absence of any statutory formula. The Tribunal found that the assessee had a business organisation in British India that promoted sales, that the groundwork for the transactions was done there, and that the contracts were completed on the record facts. Because the apportionment was based on relevant material and the circumstances of the case, it was not to be disturbed. The profit treated as accruing or arising in British India was accordingly upheld at Rs. 54,400 for the assessment year 1942-43. Case-Laws Income Tax Fri, 19 Mar 1976 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=6475