https://www.taxtmi.com/caselaws?id=291081 Accumulated foreign profits that have already been converted into capital assets are not taxable as remitted income when those assets are moved into the taxable territory as part of a contemporaneous change of investment. The sale of Mysore securities and purchase of Travancore securities was treated as a substitution of investments, with the proceeds not used for the Madras business and no device shown to bring income into British India. On those facts, the movement represented capital rather than money's worth assessable as foreign profits, so any remittance was not chargeable as income. en-us Tue, 14 Feb 1961 00:00:00 +0530 Tue, 27 Oct 2020 17:49:09 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=291081 Accumulated foreign profits that have already been converted into capital assets are not taxable as remitted income when those assets are moved into the taxable territory as part of a contemporaneous change of investment. The sale of Mysore securities and purchase of Travancore securities was treated as a substitution of investments, with the proceeds not used for the Madras business and no device shown to bring income into British India. On those facts, the movement represented capital rather than money's worth assessable as foreign profits, so any remittance was not chargeable as income. Case-Laws Income Tax Tue, 14 Feb 1961 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=291081