JUDGMENT

THOMMEN, J.:— These appeals by the assessee arise from the judgment dated 7-5-1965 of the Calcutta High Court. The question relates to the assessment for the years 1945-46, 1946-47 and 1947-48 under the Indian Income-tax Act, 1922 (hereinafter referred to as "the Act"). The assessee was a company resident in British India during the relevant years. It had a cotton mill in British India. The cloth manufactured by the mill was sold in British India as well as in the native States. In the assessment for 1944-45, it had been held that, for the sales effected in the native States, 1 / 3rd of the profit was, in terms of S. 42(3) of the Act, deemed to have accrued to the assessee in British India. This profit was considered as the profit attributed to the manufacturing part of the business carried out in British India, although the sales were effected in the native States. On the same basis, assessment in terms of Section 42(3) was made in respect of the assessment years 1945-46, 1946-47 and 1947-48. In addition to the deemed income in British India, the assessee was assessed under Section 14(2)(c) of the Act in respect of certain sums remitted to British lndia from the native St