https://www.taxtmi.com/caselaws?id=276648 Income accruing outside the taxable territories was includible under the proviso to section 4(1) of the Income-tax Act, 1922 where it was derived from a business controlled in India, and the text indicates that temporary absence of the assessee did not by itself break that control. On that basis, the Hongkong branch income was treated as fully taxable in India rather than apportioned for part of the year. For loss carry-forward, section 24(2) was described as limiting set-off to losses actually established in assessment and capable of statutory carry forward, so unproved earlier losses and losses referable to a period outside the Indian tax net were not available for set-off in the later year. en-us Sat, 08 Sep 1962 00:00:00 +0530 Thu, 15 Nov 2018 11:48:33 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=276648 Income accruing outside the taxable territories was includible under the proviso to section 4(1) of the Income-tax Act, 1922 where it was derived from a business controlled in India, and the text indicates that temporary absence of the assessee did not by itself break that control. On that basis, the Hongkong branch income was treated as fully taxable in India rather than apportioned for part of the year. For loss carry-forward, section 24(2) was described as limiting set-off to losses actually established in assessment and capable of statutory carry forward, so unproved earlier losses and losses referable to a period outside the Indian tax net were not available for set-off in the later year. Case-Laws Income Tax Sat, 08 Sep 1962 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=276648