COMMISSIONER OF INCOME-TAX, BANGALORE vs THE UNION OF TILE EXPORTS, BANGALORE

The Supreme Court upheld the High Court's decision regarding the apportionment of profits under Section 4(1)(a) of the Indian Income-tax Act, 1922, affirming that profits accrued in Bangalore, a Part B State, where the contracts were made. The Court ruled that the entire income could not be considered as arising outside the Part B State, as significant business activities occurred in Bangalore. Consequently, the assessee was entitled to the concessions provided under the Part B States (Taxation Concessions) Order, 1950.