https://www.taxtmi.com/caselaws?id=276364 The expression "transaction" in section 10A of the Excess Profits Tax Act was given a wide meaning to include any act done in the course of business, including opening a new branch or shifting business to another place. Section 10A was treated as concerned with the effect of the act on taxable profits, not its formal character, so the opening of a branch in an Indian State fell within it. The third proviso to section 5, dealing with profits accruing in Part B States, was held to operate in a different field and did not bar section 10A. An anti-avoidance adjustment could therefore be made to taxable-business profits even where diverted profits arose in an exempt territory. en-us Fri, 12 Oct 1962 00:00:00 +0530 Thu, 08 Nov 2018 11:48:59 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=276364 The expression "transaction" in section 10A of the Excess Profits Tax Act was given a wide meaning to include any act done in the course of business, including opening a new branch or shifting business to another place. Section 10A was treated as concerned with the effect of the act on taxable profits, not its formal character, so the opening of a branch in an Indian State fell within it. The third proviso to section 5, dealing with profits accruing in Part B States, was held to operate in a different field and did not bar section 10A. An anti-avoidance adjustment could therefore be made to taxable-business profits even where diverted profits arose in an exempt territory. Case-Laws Income Tax Fri, 12 Oct 1962 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=276364