https://www.taxtmi.com/caselaws?id=293357 In computing remittable profits under the Income-tax Act, prior years' losses were not an automatic deduction unless actually brought forward in the books, and depreciation on assets in a native State could not be imported without a specific provision; profits were to be understood in their commercial sense. The department had to show that profits were available for remittance, and a remittance in the ordinary course of business was only presumptively treated as trading receipt; its profit element had to be determined proportionately, not by taxing the whole amount. Where reciprocal head office and branch remittances existed, the presumption was weakened by the accounts, so only the excess representing income could be taxed. en-us Wed, 27 Jun 1962 00:00:00 +0530 Sat, 06 Feb 2021 10:26:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=293357 In computing remittable profits under the Income-tax Act, prior years' losses were not an automatic deduction unless actually brought forward in the books, and depreciation on assets in a native State could not be imported without a specific provision; profits were to be understood in their commercial sense. The department had to show that profits were available for remittance, and a remittance in the ordinary course of business was only presumptively treated as trading receipt; its profit element had to be determined proportionately, not by taxing the whole amount. Where reciprocal head office and branch remittances existed, the presumption was weakened by the accounts, so only the excess representing income could be taxed. Case-Laws Income Tax Wed, 27 Jun 1962 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=293357