https://www.taxtmi.com/caselaws?id=277308 In a simple trading business, profit accrues or arises where the sale is effected and the income is realised; mere purchase of raw goods in an Indian State and export in that state does not itself create accrued income there. On the facts, nothing beyond purchase and export was done in the States, so no part of the trading profits accrued or arose in an Indian State. As no such accrual in the States was shown, Section 42(3) of the Income-tax Act, 1922 had no basis for apportionment, and the claimed exemption under Section 14(2) also failed. en-us Tue, 23 Nov 1948 00:00:00 +0530 Sat, 01 Dec 2018 10:24:59 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=277308 In a simple trading business, profit accrues or arises where the sale is effected and the income is realised; mere purchase of raw goods in an Indian State and export in that state does not itself create accrued income there. On the facts, nothing beyond purchase and export was done in the States, so no part of the trading profits accrued or arose in an Indian State. As no such accrual in the States was shown, Section 42(3) of the Income-tax Act, 1922 had no basis for apportionment, and the claimed exemption under Section 14(2) also failed. Case-Laws Income Tax Tue, 23 Nov 1948 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=277308