https://www.taxtmi.com/caselaws?id=49266 Income accruing outside the taxable territories to a person resident but not ordinarily resident was includible only if it was derived from a business controlled in India under the proviso to section 4 of the Indian Income-tax Act, 1922. The Tribunal found, and the High Court accepted, that the Hong Kong business was controlled from India throughout the accounting year. Temporary absence of the proprietor did not displace that control, and there was no basis for apportioning the profits on a time basis. The claim for apportionment therefore failed, and the foreign business income was included in total income. en-us Tue, 14 Dec 1965 00:00:00 +0530 Mon, 18 Aug 2014 18:50:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=49266 Income accruing outside the taxable territories to a person resident but not ordinarily resident was includible only if it was derived from a business controlled in India under the proviso to section 4 of the Indian Income-tax Act, 1922. The Tribunal found, and the High Court accepted, that the Hong Kong business was controlled from India throughout the accounting year. Temporary absence of the proprietor did not displace that control, and there was no basis for apportioning the profits on a time basis. The claim for apportionment therefore failed, and the foreign business income was included in total income. Case-Laws Income Tax Tue, 14 Dec 1965 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=49266