https://www.taxtmi.com/caselaws?id=290942 Systematic lending operations carried on through Bombay were treated as business carried on in British India, so the interest income from those transactions was held to accrue or arise there under the charging scheme of the 1922 Act. However, although the Bombay company had a business connection with the non-resident Hongkong company, it could not be assessed as its agent unless it was in receipt of the income on behalf of the non-resident. Sections 40, 42(1) and 43 were read together, but the wider class of possible agents did not remove the statutory requirement of receipt on behalf of the non-resident. The Bombay company was only a borrower and debtor, so agent assessment failed. en-us Mon, 12 Mar 1928 00:00:00 +0530 Thu, 22 Oct 2020 15:53:02 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=290942 Systematic lending operations carried on through Bombay were treated as business carried on in British India, so the interest income from those transactions was held to accrue or arise there under the charging scheme of the 1922 Act. However, although the Bombay company had a business connection with the non-resident Hongkong company, it could not be assessed as its agent unless it was in receipt of the income on behalf of the non-resident. Sections 40, 42(1) and 43 were read together, but the wider class of possible agents did not remove the statutory requirement of receipt on behalf of the non-resident. The Bombay company was only a borrower and debtor, so agent assessment failed. Case-Laws Income Tax Mon, 12 Mar 1928 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=290942