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    <title>1949 (9) TMI 23 - CALCUTTA HIGH COURT</title>
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    <description>Section 42(1) of the Income-tax Act, 1922 was construed broadly to apply to resident as well as non-resident assessees, because the opening charging words were not limited by the later reference to a person not resident in British India. Section 42(3) was likewise treated as wide enough to cover a resident assessee where all operations were not carried on in British India, and to permit reasonable apportionment of profits attributable to operations in British India. The statutory scheme, including the proviso and Section 14(2)(c), supported this construction, so the apportionment under Section 42(3) was upheld.</description>
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    <pubDate>Mon, 05 Sep 1949 00:00:00 +0530</pubDate>
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      <title>1949 (9) TMI 23 - CALCUTTA HIGH COURT</title>
      <link>https://www.taxtmi.com/caselaws?id=198004</link>
      <description>Section 42(1) of the Income-tax Act, 1922 was construed broadly to apply to resident as well as non-resident assessees, because the opening charging words were not limited by the later reference to a person not resident in British India. Section 42(3) was likewise treated as wide enough to cover a resident assessee where all operations were not carried on in British India, and to permit reasonable apportionment of profits attributable to operations in British India. The statutory scheme, including the proviso and Section 14(2)(c), supported this construction, so the apportionment under Section 42(3) was upheld.</description>
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      <pubDate>Mon, 05 Sep 1949 00:00:00 +0530</pubDate>
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