1967 (1) TMI 17

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.... to income-tax for the assessment years 1951-52 and 1952-53 on his share of profits accruing in a partnership firm carrying on business in Ceylon. For the first year, his foreign income was determined to be Rs. 10,540 and for the second year, Rs. 6,500. Demands were made on the petitioner in respect of the two years on April 30, 1953. Subsequently, coercive proceedings have been taken against the ....

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....lanation to the proviso and contends that the proviso read with the Explanation shows that, if the petitioner had been negligent in taking steps to get his share repatriated into the taxable territories, it will make a difference to the validity of the coercive proceedings. We find no force in this contention. It is not the case for the revenue that in Ceylon there is no prohibition or restriction....