https://www.taxtmi.com/caselaws?id=276530 Section 42 required a composite lending arrangement in which money brought into the taxable territory formed part of a definite understanding between lender and borrower. Mere internal banking transfers between a branch and head office, or a speculative possibility that deposit funds might later be used elsewhere, was not enough. On the facts, there was no reliable evidence that the fixed deposits were specifically intended to be transferred for the assessee-mills' use, and the alternative business connection argument was also unsupported. The interest on the fixed deposits therefore could not be treated as income deemed to accrue or arise in the taxable territory, and the assessment on that basis was unsustainable. en-us Tue, 08 Jan 1963 00:00:00 +0530 Tue, 13 Nov 2018 14:10:07 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=276530 Section 42 required a composite lending arrangement in which money brought into the taxable territory formed part of a definite understanding between lender and borrower. Mere internal banking transfers between a branch and head office, or a speculative possibility that deposit funds might later be used elsewhere, was not enough. On the facts, there was no reliable evidence that the fixed deposits were specifically intended to be transferred for the assessee-mills' use, and the alternative business connection argument was also unsupported. The interest on the fixed deposits therefore could not be treated as income deemed to accrue or arise in the taxable territory, and the assessment on that basis was unsustainable. Case-Laws Income Tax Tue, 08 Jan 1963 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=276530