https://www.taxtmi.com/caselaws?id=276949 Income from manufacturing operations accrues or arises where the profit-earning operations are carried on, not merely where a company's head office or directors control its affairs. Profits generated outside British India were therefore not treated as accruing or arising in British India solely because management was in Bombay. Entries made in accounts kept in British India did not amount to receipt there, as bookkeeping cannot convert outside profits into income received within the charge. The Court also held that the broader question whether such income could be taxed as accruing in British India was a question of law within reference jurisdiction, though that did not change the substantive tax result. en-us Wed, 09 Feb 1921 00:00:00 +0530 Tue, 20 Nov 2018 17:37:10 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=276949 Income from manufacturing operations accrues or arises where the profit-earning operations are carried on, not merely where a company's head office or directors control its affairs. Profits generated outside British India were therefore not treated as accruing or arising in British India solely because management was in Bombay. Entries made in accounts kept in British India did not amount to receipt there, as bookkeeping cannot convert outside profits into income received within the charge. The Court also held that the broader question whether such income could be taxed as accruing in British India was a question of law within reference jurisdiction, though that did not change the substantive tax result. Case-Laws Income Tax Wed, 09 Feb 1921 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=276949