https://www.taxtmi.com/caselaws?id=276256 Under the second proviso to section 23(5)(a) of the Indian Income-tax Act, 1922, a non-resident partner's share in a resident registered firm was assessable on the firm without excluding income arising outside the taxable territories under section 4(1)(c), because the proviso fastened only that share income and did not import the general exclusion rule. Section 17 also applied in this setting, so the non-resident partner's share income was taxable at the maximum rate. Both issues were decided against the assessee, confirming assessment of the share income on the firm and application of the special non-resident rate. en-us Thu, 28 Jul 1960 00:00:00 +0530 Sat, 03 Nov 2018 15:15:49 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=276256 Under the second proviso to section 23(5)(a) of the Indian Income-tax Act, 1922, a non-resident partner's share in a resident registered firm was assessable on the firm without excluding income arising outside the taxable territories under section 4(1)(c), because the proviso fastened only that share income and did not import the general exclusion rule. Section 17 also applied in this setting, so the non-resident partner's share income was taxable at the maximum rate. Both issues were decided against the assessee, confirming assessment of the share income on the firm and application of the special non-resident rate. Case-Laws Income Tax Thu, 28 Jul 1960 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=276256