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1937 (9) TMI 11

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..... income amounting to ₹ 18,000 odd, which they received in London. They invested that income, or at any rate the bulk of it, in the purchase of stores and machinery in England, which they had shipped to Bombay, and the question is whether they are liable to pay income-tax on so much of the stores and machinery as represent income received by them in London; in other words, whether the income r .....

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..... ctually received. Foreign income may be received in sterling or francs or dollars, and may be brought into British India in the form of rupees, or income received abroad may be remitted to India by means of a bankers draft. To use Lord Bramptons phrase in the Gresham Case [Gresham Life Assurance Society Ltd. v. Bishop, (1903 Appeal Cases 287) I the income may be received in specie or in any form .....

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..... ich an assessee in this country, desirous of bringing into this country foreign income for use as income in India, might convert the foreign income into some form of capital by purchase of bonds or otherwise, bring the bonds to this country and then sell them and apply the proceeds as income. In such a case I apprehend the Court would probably hold that what had been brought into this country was .....

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