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5. Research or Statistical Establishments, Display Rooms, etc

115. The mere existence of these establishments in N.E.I. presents, as a rule, no grounds for taxation, unless direct selling transactions take place on the premises. When a foreign corporation has a sales establishment in this country, it is felt that any profits attributable indirectly to the existence of a display room or a statistical establishment will appear in the books of the selling establishment, and, consequently, will be included in its assessment. Should it be necessary to determine the East Indian profit by fractional apportionment, the existence of such establishments would be considered as justification for increasing the East Indian proportion.

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