Attributable Income Tax Act, 1961, Section 104(4) It is no doubt true that the words ‘‘attributable to’’ have a wider meaning than the words ‘‘derived from’’. But at the same time it cannot be ignored that normally the word ‘‘attributable’’ implies that ‘‘for a result to be attributable to anything it must be wholly, or in material part, caused by that thing’’. [See Stroud’s Judicial Dictionary, 5th Edn., Vol. I, p. 233.] A causal connection is necessary. In order that income can be said to be attributable to manufacture or processing of goods for the purpose of Explanation to Section 104(4) of the Act the earning of the income must be directly connected with manufacture or processing of goods. [India Leather Corporation (P) Ltd. v. C.I.T., (1997) 10 SCC 115 (118)]