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    <title>1966 (10) TMI 34 - Supreme Court</title>
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    <description>Section 25(3) of the Income-tax Act, 1922 was applied broadly where a discontinued foreign business had earlier been taxed under the Indian Income-tax Act, 1918. The SC held that relief was available because the entire profits of the foreign business had been received in British India and assessed under the 1918 Act, so exemption could not be refused merely because the assessment arose through remittances. The same principle extended to rental income from house properties owned by the discontinued firm, since the heads of income are only modes of computation and do not limit the source of the income. Relief was accordingly available on both questions.</description>
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    <pubDate>Fri, 14 Oct 1966 00:00:00 +0530</pubDate>
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      <title>1966 (10) TMI 34 - Supreme Court</title>
      <link>https://www.taxtmi.com/caselaws?id=39908</link>
      <description>Section 25(3) of the Income-tax Act, 1922 was applied broadly where a discontinued foreign business had earlier been taxed under the Indian Income-tax Act, 1918. The SC held that relief was available because the entire profits of the foreign business had been received in British India and assessed under the 1918 Act, so exemption could not be refused merely because the assessment arose through remittances. The same principle extended to rental income from house properties owned by the discontinued firm, since the heads of income are only modes of computation and do not limit the source of the income. Relief was accordingly available on both questions.</description>
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      <pubDate>Fri, 14 Oct 1966 00:00:00 +0530</pubDate>
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