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    <title>1945 (2) TMI 23 - MADRAS HIGH COURT</title>
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    <description>The ordinary meaning of &quot;control&quot; under the relevant proviso to section 4(1) requires actual control in British India over a foreign business; mere physical presence of the karta or manager in British India is not enough. The text states that income arising without British India remains outside assessment unless the business was controlled or set up in British India or the income was brought into British India during the year. Copies of day-books sent to British India were also insufficient where management abroad continued with the eldest son. On that basis, the question was answered in favour of the assessee.</description>
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    <pubDate>Fri, 09 Feb 1945 00:00:00 +0630</pubDate>
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      <title>1945 (2) TMI 23 - MADRAS HIGH COURT</title>
      <link>https://www.taxtmi.com/caselaws?id=275905</link>
      <description>The ordinary meaning of &quot;control&quot; under the relevant proviso to section 4(1) requires actual control in British India over a foreign business; mere physical presence of the karta or manager in British India is not enough. The text states that income arising without British India remains outside assessment unless the business was controlled or set up in British India or the income was brought into British India during the year. Copies of day-books sent to British India were also insufficient where management abroad continued with the eldest son. On that basis, the question was answered in favour of the assessee.</description>
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      <pubDate>Fri, 09 Feb 1945 00:00:00 +0630</pubDate>
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