MCGREGOR & BALFOUR LTD. vs THE COMMISSIONER OF INCOME-TAX,WEST BENGAL

The Supreme Court ruled that under Section 11(14) of the Indian Finance Act, 1946, the repayment of excess profits tax received by a company from England is deemed 'income' for the purposes of the Indian Income-tax Act. The Court held that this amount was rightly included in the taxable profits of the appellant for the assessment year 1947-48, establishing that the distinction between incomes within and outside taxable territories is rendered unnecessary by this provision. The appeal was dismissed, affirming the lower court's decision.