https://www.taxtmi.com/caselaws?id=7907 Relief from double taxation under the Indian Income-tax Act, 1922 depended on the amount falling within the statutory category of income arising without the taxable territories. The Calcutta HC held that Burma trading results from goods manufactured in India and sold in Burma could not, on the facts, be treated as such income merely because they were also taxed in Burma. Applying the principle that manufacturing profits accrue at the place of manufacture and sale profits at the place of sale, the Court found the amount did not satisfy section 49D and the Indian assessment had treated the Burma result as a loss. Relief was therefore denied and the reference was answered against the assessee. en-us Tue, 10 Jun 1969 00:00:00 +0530 Tue, 24 Mar 2009 09:44:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=7907 Relief from double taxation under the Indian Income-tax Act, 1922 depended on the amount falling within the statutory category of income arising without the taxable territories. The Calcutta HC held that Burma trading results from goods manufactured in India and sold in Burma could not, on the facts, be treated as such income merely because they were also taxed in Burma. Applying the principle that manufacturing profits accrue at the place of manufacture and sale profits at the place of sale, the Court found the amount did not satisfy section 49D and the Indian assessment had treated the Burma result as a loss. Relief was therefore denied and the reference was answered against the assessee. Case-Laws Income Tax Tue, 10 Jun 1969 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=7907