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PETITIONER: ANGLO-FRENCH TEXTILE CO. LTD.
Vs.
RESPONDENT: COMMISSIONER OF INCOME-TAX,MADRAS.
DATE OF JUDGMENT: 22/12/1952
BENCH: MAHAJAN, MEHR CHAND BENCH: MAHAJAN, MEHR CHAND DAS, SUDHI RANJAN BOSE, VIVIAN BHAGWATI, NATWARLAL H.
CITATION: 1953 AIR 105 1953 SCR 454 CITATOR INFO : C 1954 SC 198 (10,10A) R 1958 SC 269 (14) R 1958 SC 861 (15) RF 1965 SC1526 (15)
ACT: Indian Income-tax Act (XI of 1922), ss. 42(1),42(3)-Non- resident-Purchase of materials in India by established agency--Whether an " operation "-Profits attributable to purchase, whether assessable in India-"Business connection," meaning of.
HEADNOTE: Though a few isolated transactions of purchase of raw mate- rials in India by a manufacturer carrying on business outside India may not amount to the carrying on of an " operation " in India within the meaning of s. 42 (3) of the Indian Income-tax Act, where raw materials are purchased systematically and habitually in India through an established agency having special skill and competency in selecting the goods, such an activity will be an "operation" within a. 42 (3), and the portion of the profits 455 attributable to the purchases in India can be assessed to incometax under s. 42(1) and (3) of the Indian Income-tax Act. Bangalore Woollen, Cotton & Silk Mills Co. Ltd. v. Commis- sioner ...