https://www.taxtmi.com/caselaws?id=277159 A firm was treated as resident in British India under Section 4A(b) of the Income-tax Act, 1922 because its control and management were not situated wholly outside British India. The assessee had the burden of proving that the head and brain of the business operated entirely outside British India, and the decisive inquiry was where the affairs were actually controlled and managed, not where trading work was carried on. The evidence showed that partners in Trichinopoly issued directions on purchases, sales, expenditure, improvements, labour matters, budgets and reserve funds, while the Ceylon superintendent acted under their instructions and reported to them regularly. The residency condition was therefore satisfied. en-us Tue, 27 Mar 1951 00:00:00 +0530 Tue, 27 Nov 2018 14:36:52 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=277159 A firm was treated as resident in British India under Section 4A(b) of the Income-tax Act, 1922 because its control and management were not situated wholly outside British India. The assessee had the burden of proving that the head and brain of the business operated entirely outside British India, and the decisive inquiry was where the affairs were actually controlled and managed, not where trading work was carried on. The evidence showed that partners in Trichinopoly issued directions on purchases, sales, expenditure, improvements, labour matters, budgets and reserve funds, while the Ceylon superintendent acted under their instructions and reported to them regularly. The residency condition was therefore satisfied. Case-Laws Income Tax Tue, 27 Mar 1951 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=277159