TMI Blog1940 (2) TMI 16X X X X Extracts X X X X X X X X Extracts X X X X ..... at Kanadukathan in the Ramnad District. The family derives income from property and business in money-lending at Kanadukathan and also at Okkan in Burma and Klang and Malacca in the Federated Malay States. For the year of assessment 1936-37, the petitioner returned a loss of ₹ 13,828. The Income Tax Officer having examined the accounts and considered the evidence produced in support of the r ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... rs total income namely, (a) $ 5,165 being the amount credited to the folio of K.S.P.L.S.T. (b) $ 6,290 being the amount debited to the M. V. K. account. (c) ₹ 1,000 being the amount utilised for the purchase of shares in the Udumalpet Sri Venkatesa Mills Ltd. The assessee is now content to have the first question answered in the affirmative. He has also given up his conte ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... hal, but the statement was accepted by the Assistant Commissioner on appeal. On the 9th February 1936, the sum of $ 5,000 was remitted from Malacca to Sigappi Achi. This remittance was made by a hundi drawn by the M.C.T.M. Banking Corporation Ltd. of Kualalampur on its branch at Pudukotta. On 23rd March 1936 a further sum of $ 1,290 was remitted to Sigappi Achi in the same way. These two sums of $ ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... re paid for from out of the profits which had accrued to the Malacca branch; but the moneys were never received in British India. They were paid direct to Sigappi Achi transferred the money to the assessee in British India. Unless profits made abroad are received in British India there can be no question of taxation here. It seems to me that the decision in Multanchand Johurmull v. Commissioner of ..... X X X X Extracts X X X X X X X X Extracts X X X X
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