(1.) THE following questions wera referred to us by the Appellate Tribunal under Section 66(1), Income-tax Act :
(2.) THE year of assessment is 1939-40 and the accounting year is the period ending with 31-12-1938. THE accounts of the assesses were kept on mercantile basis. THE assesses is the Bangalore Wollen and Cotton and Silk Mills Co. Ltd., Bangalore, hereinafter called the "company" and the managing agents of the company are Messrs. Binny & Co. (Madras) Ltd., hereinafter called the "agents."
(3.) THE assessee appealed to the Appellate Assistant Commissioner who confirmed the assessment agreeing with the Income tax Officer. THE Appellate Tribunal also agreed with the Appellate Assistant Commissioner. THE two questions that were raised before the Tribunal were (1) that there wees no business connection of any sort of the company in British India and therefore there was no income which could be deemed to have accrued or arisen whether directly or indirectly in British India within the meaning of Section 42 (1) of the Act, and, therefore, Section 42 (3) had no application ; (2) that there was no receipt of any profits in British India within the meaning of Section 4 (1) (a). THE questions referred to us practically cover the same ground.
ABOUT US "REGENT COMPUTRONICS PVT. LTD." is a Company incorporated in 1991 under the provisions of the Companies Act, 1956. Since its inception to 1995, the Company was busy in carrying out the activities related to various Banks' Job Work..
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