Anglo French Textile Company Ltd. v. CIT

23 ITR 101Supreme Court of India1953#5471 most cited

What is Anglo French Textile Company Ltd. v. CIT authority for?

Profits attributable to a Permanent Establishment (PE) in India can be conservatively estimated, such as by applying a percentage of global profits to Indian sales, when the PE's activities in India are minimal.

21

judgments rely on this decision, according to BharatTax’s citation analysis of 366,459 Indian tax judgments — from 2007 to 2025.

Also referred to as

Anglo French Textile Company Ltd. v. CIT · 23 ITR 101 · Permanent Establishment · PE profit attribution · conservative profit estimation · India sales · global profit percentage · Section 40(a)(i)

Sections most often in play

Section 115ASection 143(3)Section 144C(13)Section 197Section 2(45)Section 206CSection 234BSection 234D
Read the full judgment

Issues it is cited on

dependent agent peproximate nexussection 10(35)service pefixed place pesection 44bbsection 44bsection 135csr expenditureweighted deductionsection 35(2ab)section 10(34)

Judgments citing Anglo French Textile Company Ltd. v. CIT

Ishikawajma-Harima Heavy Industries Ltd vs. Director of Income Tax, Mumbai

The appeal is allowed in part and to

C.A. No.-000009-000009 - 2007Supreme Court04 Jan 2007
For Respondent: Director of Income Tax, Mumbai
Section 241

…http://JUDIS.NIC.IN SUPREME COURT OF INDIA Page 1 of 27 CASE NO.: Appeal (civil) 9 of 2007 PETITIONER: Ishikawajma-Harima Heavy Industries Ltd RESPONDENT: Director of Income Tax, Mumbai DATE OF JUDGMENT: 04/01/2007 BENCH: S.B. Sinha & Dalveer Bhandari JUDGMENT: J U D G M E N T [Arising out of SLP (Civil) No.5318 of 2005] S.B. SINHA, J : Leave granted. Appellant herein is a company incorporated in Japan. It is a resident of the said country. It pays its taxes in Japan. It is engaged, inter alia, in the business of construction of storage tanks as also engineering etc. It formed a co…