https://www.taxtmi.com/caselaws?id=7595 Rule 33 of the Income-tax Rules, 1922 permits computation of a non-resident's Indian income by reference to receipts accruing or arising in the taxable territories, or by applying the proportion of such receipts to total business profits. Destination freight collected at Indian ports was treated as earned and received in India, so it formed part of Indian earnings for the statutory proportion. The commentary also notes that an investment allowance under a U.K. ratio certificate could not be imported into Indian computation as a substitute for development rebate under the Indian Income-tax Act, 1922, because the foreign allowance was not covered by the relevant circular or binding statutory directions. en-us Wed, 10 Apr 1968 00:00:00 +0530 Thu, 05 Mar 2009 12:54:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=7595 Rule 33 of the Income-tax Rules, 1922 permits computation of a non-resident's Indian income by reference to receipts accruing or arising in the taxable territories, or by applying the proportion of such receipts to total business profits. Destination freight collected at Indian ports was treated as earned and received in India, so it formed part of Indian earnings for the statutory proportion. The commentary also notes that an investment allowance under a U.K. ratio certificate could not be imported into Indian computation as a substitute for development rebate under the Indian Income-tax Act, 1922, because the foreign allowance was not covered by the relevant circular or binding statutory directions. Case-Laws Income Tax Wed, 10 Apr 1968 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=7595