COMMISSIONER OF INCOME-TAX/EXCESSPROFITS TAX, BOMBAY CITY vs MESSRS. BHOGILAL LAHERCHAND includingBATLIBOI & CO., BOMB

The Supreme Court held that under Section 42(1) of the Indian Income-tax Act, 1922, profits deemed to accrue in British India can apply to both residents and non-residents. In this case, the Income-tax Officer correctly estimated the profits of a Hindu undivided family conducting business across multiple states, determining that Rs. 37,500 of the profits were deemed to accrue in British India. The Court upheld the assessment made by the Income-tax Officer, affirming the applicability of Section 42(1) to the case at hand.