https://www.taxtmi.com/caselaws?id=290254 A non-resident's business profits are treated as taxable where the underlying trading activity is carried on in British India or deemed to accrue there, even if sale and receipt occur abroad. The article explains that London realization does not by itself defeat taxability, but a reasonable allowance must be excluded for sale and realization work performed outside British India. It also distinguishes commissions earned in London: insurance and purchase/shipment commissions with only a remote Burma connection are outside the taxable nexus, while commission linked to London sales may be charged only after deducting a reasonable agent's commission. Managing agency remuneration is taxable only to the extent it represents profit from management in British India. en-us Wed, 09 Sep 1925 00:00:00 +0530 Wed, 16 Sep 2020 11:55:07 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=290254 A non-resident's business profits are treated as taxable where the underlying trading activity is carried on in British India or deemed to accrue there, even if sale and receipt occur abroad. The article explains that London realization does not by itself defeat taxability, but a reasonable allowance must be excluded for sale and realization work performed outside British India. It also distinguishes commissions earned in London: insurance and purchase/shipment commissions with only a remote Burma connection are outside the taxable nexus, while commission linked to London sales may be charged only after deducting a reasonable agent's commission. Managing agency remuneration is taxable only to the extent it represents profit from management in British India. Case-Laws Income Tax Wed, 09 Sep 1925 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=290254