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TMI Blog1927 (12) TMI 5X X X X Extracts X X X X X X X X Extracts X X X X ..... levant ones are Madras, where his head office was, and Ipoh, a place in the Fedrated Malay States. The short point is this. Money was borrowed by the assessee in Madras and of course interest has to be paid on it in Madras. Part of that money--it does not matter how much because that is a question of fact for the Commissioner who has found a figure--was in effect sent out to Ipoh and was used as c ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ness where the payment of interest thereon is not in any way dependent on the earning of profits, the amount of the interest paid. 3. The only words that it is necessary to consider for the, purpose of this case are the words at the beginning in respect of capital borrowed for the purposes of the business . The question is, can this capital be said to be borrowed for the purposes of the busin ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... f which alone is liable to be taxed. With the argument that the capital borrowed for the purposes of the business will include any sum of money which at the moment it was borrowed was put into the coffers of the particular business in British India and that therefore it did not matter if the whole of it was taken out next day and sent to China, I do not think it is really necessary to deal, becaus ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... its of the Ipoh branch were automatically remitted to Madras and came here and that the Madras office was notionally running in its Madras Office the business at Ipoh. There is no evidence of that; on the contrary the finding of the Commissioner is that no part of the profits made during this year at Ipoh were sent from Ipoh to Madras. As my brother Beasley pointed out in the course of the argumen ..... X X X X Extracts X X X X X X X X Extracts X X X X
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