https://www.taxtmi.com/caselaws?id=276060 A statutory provision deeming repayment of foreign excess profits tax to be income created a special chargeable amount for the year of repayment and made it assessable to income-tax and super-tax. The repayment was therefore taxable under section 11(14) of the Indian Finance Act, 1946. However, that deeming rule did not convert the amount into income arising in India. For residence computation under section 4A(c)(b) of the Indian Income-tax Act, 1922, the repayment could not be counted as Indian-source income because the statute gave no basis for attributing it to India. en-us Thu, 26 Aug 1954 00:00:00 +0530 Fri, 26 Oct 2018 13:25:33 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=276060 A statutory provision deeming repayment of foreign excess profits tax to be income created a special chargeable amount for the year of repayment and made it assessable to income-tax and super-tax. The repayment was therefore taxable under section 11(14) of the Indian Finance Act, 1946. However, that deeming rule did not convert the amount into income arising in India. For residence computation under section 4A(c)(b) of the Indian Income-tax Act, 1922, the repayment could not be counted as Indian-source income because the statute gave no basis for attributing it to India. Case-Laws Income Tax Thu, 26 Aug 1954 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=276060