https://www.taxtmi.com/caselaws?id=49703 Actual receipt of income in India under section 4(1)(a) was held to exclude the deeming fiction in section 42(1) of the Indian Income-tax Act, 1922, so section 42 had no application where taxability rested on receipt. For section 4A(c)(b), income could not automatically be treated as wholly arising in India merely because it was received there; in a composite business, profits had to be apportioned according to the distinct profit-producing operations carried on within and outside the taxable territory. The analysis affirmed that manufacturing and sales operations may generate income in different places, requiring business-like apportionment. en-us Tue, 08 Dec 1953 00:00:00 +0530 Tue, 17 Feb 2015 10:55:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=49703 Actual receipt of income in India under section 4(1)(a) was held to exclude the deeming fiction in section 42(1) of the Indian Income-tax Act, 1922, so section 42 had no application where taxability rested on receipt. For section 4A(c)(b), income could not automatically be treated as wholly arising in India merely because it was received there; in a composite business, profits had to be apportioned according to the distinct profit-producing operations carried on within and outside the taxable territory. The analysis affirmed that manufacturing and sales operations may generate income in different places, requiring business-like apportionment. Case-Laws Income Tax Tue, 08 Dec 1953 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=49703