https://www.taxtmi.com/caselaws?id=198004 Whether apportionment under Section 42 applies to residents was decided by analysing statutory language and scheme: the general wording of s.42(1) and the wide framing of s.42(3) show they operate in respect of both residents and non residents; the first proviso expressly addressing non residents indicates an exception rather than exclusivity; s.42(2)'s explicit restriction to non residents shows the Legislature knew how to limit provisions; Section 14(2)(c) and amendment history (marginal note revision) support applying s.42 to residents, permitting attribution of profits reasonably attributable to operations in British India. en-us Mon, 05 Sep 1949 00:00:00 +0530 Sat, 20 Jan 2018 12:54:22 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=198004 Whether apportionment under Section 42 applies to residents was decided by analysing statutory language and scheme: the general wording of s.42(1) and the wide framing of s.42(3) show they operate in respect of both residents and non residents; the first proviso expressly addressing non residents indicates an exception rather than exclusivity; s.42(2)'s explicit restriction to non residents shows the Legislature knew how to limit provisions; Section 14(2)(c) and amendment history (marginal note revision) support applying s.42 to residents, permitting attribution of profits reasonably attributable to operations in British India. Case-Laws Income Tax Mon, 05 Sep 1949 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=198004