Supreme Court · 1971 INSC 185 · Decided 9 August 1971

C.A.P. Andiappan v. C.I.T. Madras & Anr

Court
Supreme Court of India
Citation
1971 INSC 185 · [1972] 1 S.C.R. 88
Case number
CIVIL APPEAL No. 1689/1968
Decided
9 August 1971
Bench
K.S. HEGDE, A.N. GROVER (2-judge bench)
Outcome
Dismissed
Case type
Civil
Acts & sections cited
Constitution Article 226, 133(l)(c); Income Tax Act Section 49A, 49C

Headnote

Income-tax Act (11 of J 922). s. 49A-Agreement between h1d;a and Ceylon, Art 3, ;rem 8-Scope of-Relief under qey!on Income-tax Ordinance 1932 s. 45(2)-Abatement to wl11c/1 a!1 assessee res;dent ;,i Ind;a and carry;,1g on business in Ceylon rs elllitled to. The appellant was a resident in India and and 1960-61 was what he earned in Ceylon. He was liable to be assessed as a non-resident, but, in view of s. 45(2) of the Ceylon Inco~e-tax Ordinance, 1932, and of the Agreement for 'Assess~ent for Re!Jef or for Avoidance of Double Taxation in India and Ceylon' as prov1ded ·in s. 49A

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