https://www.taxtmi.com/caselaws?id=190007 Profits realised on sales effected in British India qualify as income arising in British India for residence determination; the court held the distinction between actual income arising in the territory and income deemed to arise under the statutory apportionment rule is material, so the apportionment mechanism applicable to deemed income does not apply to actual profits. Applying the charging provisions, profit arises on sale and is measured by sale proceeds less allowable costs (including cost of manufacture and transport); therefore manufacturing performed outside the territory does not automatically carve out part of sale profits for residence purposes, and the Commissioner's position is upheld. 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 effected in British India qualify as income arising in British India for residence determination; the court held the distinction between actual income arising in the territory and income deemed to arise under the statutory apportionment rule is material, so the apportionment mechanism applicable to deemed income does not apply to actual profits. Applying the charging provisions, profit arises on sale and is measured by sale proceeds less allowable costs (including cost of manufacture and transport); therefore manufacturing performed outside the territory does not automatically carve out part of sale profits for residence purposes, and the Commissioner's position is upheld. Case-Laws Income Tax Wed, 14 Dec 1949 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=190007