https://www.taxtmi.com/caselaws?id=277159 Presumption under Section 4A(b) treats a firm as resident in British India unless its control and management is wholly situated abroad, with the onus on the assessee to prove otherwise. 'Control and management' is the de facto controlling and directive power, capable of being divided between places and judged by actual operations. Here, partners resident in Trichinopoly issued regular instructions and supervised vital management functions while a superintendent in Ceylon carried out local operations; therefore key management remained in British India and the firm was held resident in British India. 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 Presumption under Section 4A(b) treats a firm as resident in British India unless its control and management is wholly situated abroad, with the onus on the assessee to prove otherwise. 'Control and management' is the de facto controlling and directive power, capable of being divided between places and judged by actual operations. Here, partners resident in Trichinopoly issued regular instructions and supervised vital management functions while a superintendent in Ceylon carried out local operations; therefore key management remained in British India and the firm was held resident in British India. Case-Laws Income Tax Tue, 27 Mar 1951 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=277159