COMMISSIONER OF INCOME TAX Vs. RM AL CT ANNAMALAI CHETTIAR

JUDGEMENT

(1.) THE assessee is a Nattukottai Chettiar who was carrying on a money-lending business at Kajang in the Federated Malay States. In the year of account he instructed the Indian Overseas Bank, Limited, at Kualalumpur to remit to its as a fixed deposit of the assessee, repayable at the end of twelve months. THE money which the assessee paid into the bank at Kualalumpur when he gave those instructions represented profits which the assessee had made at Kajang. This is not disputed. When the deposit matured the amount was paid to the assessee at Karaikudi. In these circumstances the Income-tax Officer held that the remittance from Kualalumpur represented a remittance of profits made by the assessee at Kajang and included this amount in the assessment.