https://www.taxtmi.com/caselaws?id=39110 A firm was treated as resident under section 4A(b) of the Indian Income-tax Act, 1922 because its control and management were not shown to be wholly outside the taxable territories. The presumption of non-residence was rebutted by correspondence showing that a partner in India negotiated and settled contractual terms, directed delivery and labelling, and acted as the firm's effective representative. Those acts, binding on the firm under the Partnership Act, demonstrated de facto control and management exercised at least partly within India, so section 18(3B) read with section 18(7) applied and the tax direction was upheld. en-us Sat, 24 Mar 1973 00:00:00 +0530 Tue, 13 Apr 2010 10:23:25 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=39110 A firm was treated as resident under section 4A(b) of the Indian Income-tax Act, 1922 because its control and management were not shown to be wholly outside the taxable territories. The presumption of non-residence was rebutted by correspondence showing that a partner in India negotiated and settled contractual terms, directed delivery and labelling, and acted as the firm's effective representative. Those acts, binding on the firm under the Partnership Act, demonstrated de facto control and management exercised at least partly within India, so section 18(3B) read with section 18(7) applied and the tax direction was upheld. Case-Laws Income Tax Sat, 24 Mar 1973 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=39110