TMI Blog1932 (2) TMI 27X X X X Extracts X X X X X X X X Extracts X X X X ..... on the Port Said Salt Association, Ltd., for the years 1928-29 and 1929-30. The assessees have their headquarters in Egypt where they manufacture salt and export it to various parts of the world including India. They do not contest that they are liable to pay income tax under Section 42 of the Act (11 of 1922), but they have raised before the Commissioner and he has referred to us the following qu ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the circumstance that work was done and money spent abroad in order to obtain it. Naturally the cost to the assessees, wherever incurred, of producing the article, transporting it and selling it, must be deducted from the price obtained before the balance can be called a profit. Again upon a valuation of stock in hand the Egyptian business might be well entitled to treat it as an asset for more t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... person through or from any business-connexion or property in British India shall be deemed to come within the class of profits taxed by Section 4. Sub-section 3 shows that profits arising from sale of merchandise exported to British India are within the class that has been made taxable under Section 4. To permit of the assessee's contention both subsections must be drafted very differently, an ..... X X X X Extracts X X X X X X X X Extracts X X X X
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