COMMISSIONER OF INCOME-TAX, BOMBAY vs AHMEDBHAI UMARBHAI & CO., BOMBAY.

The Supreme Court interpreted Section 5 of the Excess Profits Tax Act, 1940, determining that the phrase 'part of a business' encompasses specific operations rather than requiring a complete business unit. The Court held that profits from oil manufactured in Raichur, even when sold in Bombay, accrued in Raichur and were thus exempt from excess profits tax under the proviso to Section 5. Additionally, it was found that Section 42(1) of the Indian Income-tax Act, 1922, applied to the assessees, necessitating profit apportionment between manufacturing and selling operations.