https://www.taxtmi.com/caselaws?id=39390 Income attributable to a foreign recipient may be apportioned under section 42(3) of the Indian Income-tax Act, 1922 where the contractual operations are carried on partly abroad and partly in India. The agreement here required the foreign company to furnish technical knowledge, improvements, and manufacturing developments from outside India as well as within India; the reference to production in India was only a payment-computation mechanism. On those findings, the relevant operations were not confined exclusively to India, so apportionment was attracted and the question was answered in favour of the assessee. en-us Wed, 27 Nov 1974 00:00:00 +0530 Fri, 16 Apr 2010 11:44:08 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=39390 Income attributable to a foreign recipient may be apportioned under section 42(3) of the Indian Income-tax Act, 1922 where the contractual operations are carried on partly abroad and partly in India. The agreement here required the foreign company to furnish technical knowledge, improvements, and manufacturing developments from outside India as well as within India; the reference to production in India was only a payment-computation mechanism. On those findings, the relevant operations were not confined exclusively to India, so apportionment was attracted and the question was answered in favour of the assessee. Case-Laws Income Tax Wed, 27 Nov 1974 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=39390