https://www.taxtmi.com/caselaws?id=277381 A non-resident firm's profits accrued and received in France were not taxable in British India merely because it carried on buying operations through a resident agent in Madras. Section 5 was treated as the charging provision, while section 33(1) was confined to machinery for assessment through an agent and could not, without clear words, expand the tax charge to income arising wholly outside the taxing territory. The Court applied the rule that a tax burden must rest on express statutory language and held that a buying agency in British India did not by itself create taxability of the foreign profits. en-us Mon, 30 Oct 1922 00:00:00 +0530 Mon, 03 Dec 2018 11:21:02 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=277381 A non-resident firm's profits accrued and received in France were not taxable in British India merely because it carried on buying operations through a resident agent in Madras. Section 5 was treated as the charging provision, while section 33(1) was confined to machinery for assessment through an agent and could not, without clear words, expand the tax charge to income arising wholly outside the taxing territory. The Court applied the rule that a tax burden must rest on express statutory language and held that a buying agency in British India did not by itself create taxability of the foreign profits. Case-Laws Income Tax Mon, 30 Oct 1922 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=277381