https://www.taxtmi.com/caselaws?id=277338 Sale proceeds of salt collected in India by the Indian agent were treated as income received in India on behalf of the non-resident owner, so the amount was chargeable to income-tax under the charging provisions without needing Section 42. For excess profits tax, the profits were regarded as arising through a business connection in India, but because part of the operations took place outside India, only the profit reasonably attributable to Indian operations could be taxed under the apportionment rule in Section 42(3). The result sustained receipt-based taxation for income-tax while limiting excess profits tax to the Indian element. en-us Tue, 25 Jul 1950 00:00:00 +0530 Sat, 01 Dec 2018 12:39:07 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=277338 Sale proceeds of salt collected in India by the Indian agent were treated as income received in India on behalf of the non-resident owner, so the amount was chargeable to income-tax under the charging provisions without needing Section 42. For excess profits tax, the profits were regarded as arising through a business connection in India, but because part of the operations took place outside India, only the profit reasonably attributable to Indian operations could be taxed under the apportionment rule in Section 42(3). The result sustained receipt-based taxation for income-tax while limiting excess profits tax to the Indian element. Case-Laws Income Tax Tue, 25 Jul 1950 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=277338