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    <title>1969 (6) TMI 20 - CALCUTTA High Court</title>
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    <description>Residence status under section 4A(a)(iii) turned on whether the assessee&#039;s 1947 presence was casual or occasional; on the materials, he failed to prove that it was, so he was treated as resident but not ordinarily resident for 1948-49. Remittances brought into India were also treated as taxable remittances under section 4(1)(b)(iii) because the surrounding facts showed accumulated profits, no business necessity for the transfer, and no satisfactory proof that the funds were capital. The reference was answered for the Revenue.</description>
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    <pubDate>Mon, 02 Jun 1969 00:00:00 +0530</pubDate>
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      <title>1969 (6) TMI 20 - CALCUTTA High Court</title>
      <link>https://www.taxtmi.com/caselaws?id=8668</link>
      <description>Residence status under section 4A(a)(iii) turned on whether the assessee&#039;s 1947 presence was casual or occasional; on the materials, he failed to prove that it was, so he was treated as resident but not ordinarily resident for 1948-49. Remittances brought into India were also treated as taxable remittances under section 4(1)(b)(iii) because the surrounding facts showed accumulated profits, no business necessity for the transfer, and no satisfactory proof that the funds were capital. The reference was answered for the Revenue.</description>
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