https://www.taxtmi.com/caselaws?id=273151 Profits are taxable or exempt according to where they accrue or arise, not merely where sale proceeds are realised. On the scheme of the third proviso to section 5 of the Excess Profits Tax Act, read with the apportionment principle in section 42(3) of the Income-tax Act, a substantial and separable part of the business carried on in Mysore and Cochin could generate attributable profits outside British India. The purchase, transport and loading of goats and sheep in the Indian States formed a distinct commercial segment of the business. The profits attributable to that segment were therefore exempt from excess profits tax, while the balance of the profits remained taxable. en-us Tue, 27 Mar 1951 00:00:00 +0530 Fri, 08 Jun 2018 16:39:05 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=273151 Profits are taxable or exempt according to where they accrue or arise, not merely where sale proceeds are realised. On the scheme of the third proviso to section 5 of the Excess Profits Tax Act, read with the apportionment principle in section 42(3) of the Income-tax Act, a substantial and separable part of the business carried on in Mysore and Cochin could generate attributable profits outside British India. The purchase, transport and loading of goats and sheep in the Indian States formed a distinct commercial segment of the business. The profits attributable to that segment were therefore exempt from excess profits tax, while the balance of the profits remained taxable. Case-Laws Income Tax Tue, 27 Mar 1951 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=273151