https://www.taxtmi.com/caselaws?id=200784 Section 4-A(c) of the Indian Income-tax Act, 1922 was treated as a valid machinery provision: the Bombay HC held that the Legislature could deem company residence and allocate income for tax purposes, and the provision was not invalid merely because it had incidental extra-territorial effect where a sufficient territorial nexus existed. The court also held that the amended provision applied to the assessee's 1939-40 assessment by reference to the relevant previous year, without impermissible retrospectivity. On jurisdiction, the Additional Income-tax Officer was found competent under section 64(1) because the assessee was linked to a Bombay firm carrying on business in the relevant area. The challenge failed and the assessment stood. en-us Thu, 22 Jul 1943 00:00:00 +0630 Mon, 23 Apr 2018 15:38:44 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=200784 Section 4-A(c) of the Indian Income-tax Act, 1922 was treated as a valid machinery provision: the Bombay HC held that the Legislature could deem company residence and allocate income for tax purposes, and the provision was not invalid merely because it had incidental extra-territorial effect where a sufficient territorial nexus existed. The court also held that the amended provision applied to the assessee's 1939-40 assessment by reference to the relevant previous year, without impermissible retrospectivity. On jurisdiction, the Additional Income-tax Officer was found competent under section 64(1) because the assessee was linked to a Bombay firm carrying on business in the relevant area. The challenge failed and the assessment stood. Case-Laws Income Tax Thu, 22 Jul 1943 00:00:00 +0630 https://www.taxtmi.com/caselaws?id=200784