https://www.taxtmi.com/caselaws?id=190007 Profits realised on sales in British India were treated as income arising in British India under Section 4A(c)(b) of the Income-tax Act because the business was an integrated manufacturing-and-selling concern and the profits emerged only on sale. The manufacturing stage did not create a separate taxable profit, and the Act contained no basis for splitting one business profit into manufacturing and selling components for residential-status purposes. Income deemed to accrue or arise under Section 42 was also distinguished from income actually arising, with apportionment confined to the former class. The result was that the company was resident in British India for the relevant year. en-us Wed, 14 Dec 1949 00:00:00 +0530 Tue, 31 Jan 2017 16:09:24 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=190007 Profits realised on sales in British India were treated as income arising in British India under Section 4A(c)(b) of the Income-tax Act because the business was an integrated manufacturing-and-selling concern and the profits emerged only on sale. The manufacturing stage did not create a separate taxable profit, and the Act contained no basis for splitting one business profit into manufacturing and selling components for residential-status purposes. Income deemed to accrue or arise under Section 42 was also distinguished from income actually arising, with apportionment confined to the former class. The result was that the company was resident in British India for the relevant year. Case-Laws Income Tax Wed, 14 Dec 1949 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=190007