https://www.taxtmi.com/caselaws?id=49747 A distinct manufacturing operation may constitute a "part of a business" for the third proviso to Section 5 of the Excess Profits Tax Act, 1940, where the business structure permits separate attribution of profits. Applying the apportionment machinery reflected in Section 42(3) of the Indian Income-tax Act, 1922, the Court treated manufacture and sale as separable stages of profit-making and held that profit attributable to manufacture can accrue or arise at the place of manufacture, not only at the place of sale. On that basis, the Raichur manufacturing activity was treated as arising in an Indian State and outside excess profits tax. en-us Thu, 04 May 1950 00:00:00 +0530 Fri, 04 Jul 2025 16:35:12 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=49747 A distinct manufacturing operation may constitute a "part of a business" for the third proviso to Section 5 of the Excess Profits Tax Act, 1940, where the business structure permits separate attribution of profits. Applying the apportionment machinery reflected in Section 42(3) of the Indian Income-tax Act, 1922, the Court treated manufacture and sale as separable stages of profit-making and held that profit attributable to manufacture can accrue or arise at the place of manufacture, not only at the place of sale. On that basis, the Raichur manufacturing activity was treated as arising in an Indian State and outside excess profits tax. Case-Laws Income Tax Thu, 04 May 1950 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=49747