https://www.taxtmi.com/caselaws?id=290231 Profits from the first six loan items were treated as attributable to the non-resident bank through a business connection in British India under Section 42(1), because the resident bank and non-resident bank were effectively controlled by the same family, the resident bank was substantially financed by the non-resident bank, and the lending arrangement was continuous rather than isolated. The Court stated that a business connection need not arise from contracts made in British India and may be inferred from a continuing course of dealings and practical control over the flow of business. The Bentong office was only a nominal conduit, so the income was regarded as accruing or arising through that business connection and assessment through the resident bank as agent was valid. en-us Thu, 17 Nov 1938 00:00:00 +0530 Tue, 15 Sep 2020 12:19:09 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=290231 Profits from the first six loan items were treated as attributable to the non-resident bank through a business connection in British India under Section 42(1), because the resident bank and non-resident bank were effectively controlled by the same family, the resident bank was substantially financed by the non-resident bank, and the lending arrangement was continuous rather than isolated. The Court stated that a business connection need not arise from contracts made in British India and may be inferred from a continuing course of dealings and practical control over the flow of business. The Bentong office was only a nominal conduit, so the income was regarded as accruing or arising through that business connection and assessment through the resident bank as agent was valid. Case-Laws Income Tax Thu, 17 Nov 1938 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=290231