COMMISSIONER OF INCOME TAX Vs. SARATHY PALAYACOT CO

JUDGEMENT

(1.) SARATHY Palayacot Co., Cuddalore, is a registered firm. It has a branch at Singapore. It manufactures goods at Madras and effects sale of its products at Singapore, through its branch there.

(2.) IN computing the income of the previous year ended April 13, 1974, corresponding to the assessment year 1975-76, the assessee's assessable profits at the branch at Singapore were to the tune of 1,07,339 Singapore dollars, which were converted in INdian currency at Rs. 244 per hundred Singapore dollars and valued at Rs. 1,69,143 in the profit and loss adjustment statement.

(3.) ARGUMENTS of Mr. S.V. Subramaniam, learned senior standing counsel for income-tax cases, representing the Revenue, and Mr. R. Kannan learned counsel appearing for the assessee, were heard.