63. In V.V.R.N.M. Subbayya Chettiar v. CIT

Commissioner of Income Tax- Delhi vs. M/S Pasupati Nath Commr. P. Ltd

The appeals are allowed with costs of Rs

Bench: HON'BLE DR. JUSTICE S.MURALIDHAR,HON'BLE MR. JUSTICE VIBHU BAKHRU

…sengers resident abroad. Where the brain which controls the operations from which the profits and gains arise is in this country, the trade or business is, at any rate partly, carried on in this country.’ 63. In V.V.R.N.M. Subbayya Chettiar v. CIT [1951] 19 ITR 168 (SC) it was held by the Supreme Court that in case of dual residence, it is necessary to show that the company performed some of the vital organic functions incidental to its existence as such in both the places, so that in fact there are two centres of management. The Appellant was a karta of an HUF and permanently lived in Colombo, with the…

Commissioner of Income Tax Del vs. M/S Swastik Commercial P. Ltd

The appeals are allowed with costs of Rs

Bench: HON'BLE DR. JUSTICE S.MURALIDHAR,HON'BLE MR. JUSTICE VIBHU BAKHRU

…sengers resident abroad. Where the brain which controls the operations from which the profits and gains arise is in this country, the trade or business is, at any rate partly, carried on in this country.’ 63. In V.V.R.N.M. Subbayya Chettiar v. CIT [1951] 19 ITR 168 (SC) it was held by the Supreme Court that in case of dual residence, it is necessary to show that the company performed some of the vital organic functions incidental to its existence as such in both the places, so that in fact there are two centres of management. The Appellant was a karta of an HUF and permanently lived in Colombo, with the…

Commissioner of Income Tax Del vs. M/S Trishul Commercial P. Ltd

The appeals are allowed with costs of Rs

Bench: HON'BLE DR. JUSTICE S.MURALIDHAR,HON'BLE MR. JUSTICE VIBHU BAKHRU

…sengers resident abroad. Where the brain which controls the operations from which the profits and gains arise is in this country, the trade or business is, at any rate partly, carried on in this country.’ 63. In V.V.R.N.M. Subbayya Chettiar v. CIT [1951] 19 ITR 168 (SC) it was held by the Supreme Court that in case of dual residence, it is necessary to show that the company performed some of the vital organic functions incidental to its existence as such in both the places, so that in fact there are two centres of management. The Appellant was a karta of an HUF and permanently lived in Colombo, with the…

Commissioner of Income Tax- Delhi vs. M/S Mansarover Commercial P. Ltd

The appeals are allowed with costs of Rs

Bench: HON'BLE DR. JUSTICE S.MURALIDHAR,HON'BLE MR. JUSTICE VIBHU BAKHRU

…sengers resident abroad. Where the brain which controls the operations from which the profits and gains arise is in this country, the trade or business is, at any rate partly, carried on in this country.’ 63. In V.V.R.N.M. Subbayya Chettiar v. CIT [1951] 19 ITR 168 (SC) it was held by the Supreme Court that in case of dual residence, it is necessary to show that the company performed some of the vital organic functions incidental to its existence as such in both the places, so that in fact there are two centres of management. The Appellant was a karta of an HUF and permanently lived in Colombo, with the…

Commissioner of Income Tax Del vs. M/S Soverign Commercial P. Ltd

The appeals are allowed with costs of Rs

Bench: HON'BLE DR. JUSTICE S.MURALIDHAR,HON'BLE MR. JUSTICE VIBHU BAKHRU

…sengers resident abroad. Where the brain which controls the operations from which the profits and gains arise is in this country, the trade or business is, at any rate partly, carried on in this country.’ 63. In V.V.R.N.M. Subbayya Chettiar v. CIT [1951] 19 ITR 168 (SC) it was held by the Supreme Court that in case of dual residence, it is necessary to show that the company performed some of the vital organic functions incidental to its existence as such in both the places, so that in fact there are two centres of management. The Appellant was a karta of an HUF and permanently lived in Colombo, with the…

Commissioner of Income Tax Del vs. M/S Soverign Commercial P. Ltd

The appeals are allowed with costs of Rs

…sengers resident abroad. Where the brain which controls the operations from which the profits and gains arise is in this country, the trade or business is, at any rate partly, carried on in this country.’ 63. In V.V.R.N.M. Subbayya Chettiar v. CIT [1951] 19 ITR 168 (SC) it was held by the Supreme Court that in case of dual residence, it is necessary to show that the company performed some of the vital organic functions incidental to its existence as such in both the places, so that in fact there are two centres of management. The Appellant was a karta of an HUF and permanently lived in Colombo, with the…

Commissioner of Income Tax Del vs. M/S Swastik Commercial P. Ltd

The appeals are allowed with costs of Rs

…sengers resident abroad. Where the brain which controls the operations from which the profits and gains arise is in this country, the trade or business is, at any rate partly, carried on in this country.’ 63. In V.V.R.N.M. Subbayya Chettiar v. CIT [1951] 19 ITR 168 (SC) it was held by the Supreme Court that in case of dual residence, it is necessary to show that the company performed some of the vital organic functions incidental to its existence as such in both the places, so that in fact there are two centres of management. The Appellant was a karta of an HUF and permanently lived in Colombo, with the…

Commissioner of Income Tax Del vs. M/S Trishul Commercial P. Ltd

The appeals are allowed with costs of Rs

…sengers resident abroad. Where the brain which controls the operations from which the profits and gains arise is in this country, the trade or business is, at any rate partly, carried on in this country.’ 63. In V.V.R.N.M. Subbayya Chettiar v. CIT [1951] 19 ITR 168 (SC) it was held by the Supreme Court that in case of dual residence, it is necessary to show that the company performed some of the vital organic functions incidental to its existence as such in both the places, so that in fact there are two centres of management. The Appellant was a karta of an HUF and permanently lived in Colombo, with the…

Commissioner of Income Tax- Delhi vs. M/S Pasupati Nath Commr. P. Ltd

The appeals are allowed with costs of Rs

…sengers resident abroad. Where the brain which controls the operations from which the profits and gains arise is in this country, the trade or business is, at any rate partly, carried on in this country.’ 63. In V.V.R.N.M. Subbayya Chettiar v. CIT [1951] 19 ITR 168 (SC) it was held by the Supreme Court that in case of dual residence, it is necessary to show that the company performed some of the vital organic functions incidental to its existence as such in both the places, so that in fact there are two centres of management. The Appellant was a karta of an HUF and permanently lived in Colombo, with the…