1965 (2) TMI 8 - SC - Income Tax

Whether, on the facts and in the circumstances of the case, the sums of ₹ 12,68,460, ₹ 4,40,878 and ₹ 6,71,735, or any them, which represents receipts by the assessee-company of its sale proceeds in British India, include any portion of its income in British India ?

Held that:- Having carefully weighed the pros and cons of the controversy which have been pressed before us on the present occasion, we are not satisfied that a case has been made out to review and revise our decisions in the case of the New Jehangir Mills [1959 (5) TMI 4 - SUPREME Court] and the case of the Petlad Co. Ltd.[1962 (11) TMI 45 - SUPREME COURT] That is why we think that the contention raised by Mr. Palkhivala must be upheld. In the result, the order passed by the High Court is set aside and the matter is sent back to the High Court with a direction that the High Court s