https://www.taxtmi.com/caselaws?id=277377 Profits attributable to a manufacturing segment may accrue or arise at the place where manufacture is completed, even if the wider business is treated as one business and sale occurs elsewhere. The Raichur manufacturing activity was treated as a distinct operational part of the assessee's business in an Indian State, so profits referable to that activity fell within the third proviso to Section 5 of the Excess Profits Tax Act, 1940. Where the taxing provision was doubtful, it was construed in favour of the assessee. The result was that the profits of the Raichur activity were treated as accruing or arising in the Indian State for excess profits tax purposes. en-us Wed, 17 Mar 1948 00:00:00 +0530 Mon, 03 Dec 2018 10:59:52 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=277377 Profits attributable to a manufacturing segment may accrue or arise at the place where manufacture is completed, even if the wider business is treated as one business and sale occurs elsewhere. The Raichur manufacturing activity was treated as a distinct operational part of the assessee's business in an Indian State, so profits referable to that activity fell within the third proviso to Section 5 of the Excess Profits Tax Act, 1940. Where the taxing provision was doubtful, it was construed in favour of the assessee. The result was that the profits of the Raichur activity were treated as accruing or arising in the Indian State for excess profits tax purposes. Case-Laws Income Tax Wed, 17 Mar 1948 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=277377