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    <title>1952 (12) TMI 3 - Supreme Court</title>
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    <description>A continuous business relationship between a non-resident and an established agency in British India can amount to a business connection where the agency regularly and systematically carries out material procurement operations with skill, responsibility, and control over part of the business process. On the facts stated, the assessee&#039;s regular agency for buying raw materials in British India satisfied that test, and the connection was held established. Profits may also be reasonably attributed to operations in British India when the purchase of raw materials is a habitual and contributing stage in earning the profits. The Indian purchasing activity therefore justified apportionment of profits against the assessee.</description>
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    <pubDate>Mon, 22 Dec 1952 00:00:00 +0530</pubDate>
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      <title>1952 (12) TMI 3 - Supreme Court</title>
      <link>https://www.taxtmi.com/caselaws?id=49727</link>
      <description>A continuous business relationship between a non-resident and an established agency in British India can amount to a business connection where the agency regularly and systematically carries out material procurement operations with skill, responsibility, and control over part of the business process. On the facts stated, the assessee&#039;s regular agency for buying raw materials in British India satisfied that test, and the connection was held established. Profits may also be reasonably attributed to operations in British India when the purchase of raw materials is a habitual and contributing stage in earning the profits. The Indian purchasing activity therefore justified apportionment of profits against the assessee.</description>
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      <pubDate>Mon, 22 Dec 1952 00:00:00 +0530</pubDate>
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