HUKAM CHAND MILLS LTD. INDORE vs COMMISSIONER OF INCOME TAX, BOMBAY

The Supreme Court held that the determination of the quantum of profits from sales in British India under the Income Tax Act, 1922, is a factual question dependent on the circumstances of each case. The Court affirmed that in the absence of a statutory formula, the Tribunal's findings on profit apportionment should be based on relevant material and not disturbed unless arbitrary. The Court accepted the Tribunal's calculation of profits amounting to Rs. 54,400 for the assessment year 1942-43, thereby ruling in favor of the appellant company.