1925 (9) TMI 6

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....wing to the ambiguity in the language used by the Commissioner in passing his order on the petition. The second paragraph of his order was on the face of it capable of the construction that he had held in the circumstances of this case that where any sum of money passed from a foreign business to the head-quarters of the firm in British India it must be regarded as profits and that no evidence was....

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....f proof rested upon tie assessee appears to be amply borne out by the case of Scottish Provident Institution v. Allan 88 L.T. 478 : 67 J.P. 341. That was a case of a Scottish Insurance Company, with branches in Australia, and in dealing with the question whether remittances from Australia to the head office in Scotland were assessable to Income Tax, Lord Halsbury uses the N following language:--"T....