Produce Exchange Corporation Ltd. v. CIT

77 ITR 739Supreme Court of India1970#5565 most cited

What is Produce Exchange Corporation Ltd. v. CIT authority for?

Interconnection, interlacing, and unity of control and management, along with common decision-making mechanisms and use of common funds, establish that different business activities are part of the same business. This interdependence means they cannot be treated as separate businesses, even if one can be stopped without affecting the other.

21

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 1996 to 2023.

Also referred to as

Produce Exchange Corporation Ltd. v. CIT · 77 ITR 739 · SC · interconnection · interlacing · unity of control · common management · common business · common administration · common fund · same business · business activities

Sections most often in play

Section 143(3)Section 144C(13)Section 80A(6)Section 80IASection 80IA(8)

Issues it is cited on

revenue expenditurepersoncompanybusinessindiainterest

Judgments citing Produce Exchange Corporation Ltd. v. CIT

AMERIPRISE INDIA PVT. LTD.,NEW DELHI vs. DCIT, NEW DELHI

In the result, the appeal of the assessee is allowed

ITA 1198/DEL/2016[2011-12]Status: DisposedITAT Delhi17 Jul 2023AY 2011-12

Bench: Sh. Saktijit Deydr. B. R. R. Kumar

For Appellant: Sh. Kamal Sawhney Adv. &For Respondent: Sh. P. Praveen Sidharth, CIT DR
Section 143(3)Section 234CSection 271(1)(c)Section 37(1)

…in this case by the existence of common management, common business organisation, common administration, common fund and a common place of business.” 13. The said decision was followed by the Supreme Court in Product Exchange Corporation Ltd. Vs. CIT (1970) 77 ITR 739 (SC) 14. Reliance in this regard is also placed on the Hon’ble Supreme Court decision in the case of B.R. Limited Vs. Gupta (VP) (113 ITR 647) wherein it was held as under: "In support of his conclusion that the two businesses are different, the Commissioner relies on the circumstances that "there is a distinct and marked difference in the natur…

DCIT 1(2), MUMBAI vs. MAHARSHTRA STATE ELECTRICITY BOARD, MUMBAI

In the result , the Cross Objections preferred by the assessee for the Asst Year 2004-05 is partly allowed and Cross Objections preferred by the assessee for the Asst Year 2005-06 is allowed

ITA 1649/MUM/2010[2004-05]Status: DisposedITAT Mumbai21 Apr 2021AY 2004-05
Section 143(3)Section 69

…IN THE INCOME TAX APPELLATE TRIBUNAL, ‘B BENCH MUMBAI BEFORE: SHRI M. BALAGANESH, AM & SHRI RAVISH SOOD, JM & DCIT – 1(2), Mumbai Vs. M/s. Maharashtra State R.No.535, 5th Floor Electricity Board B.A. Section, 6th Floor, Aayakar Bhavan M.K.Road, Mumbai -400020 Prakashganga, Plot No.C- 19, ‘E’ Block, Bandra Kurla Complex, Bandra (E) Mumbai – 400 051 PAN/GIR No. AAACM7507P (Appellant) .. (Respondent) CO No.198/Mum/2010 (Arising out of ITA No.1649/Mum/2010) (Assessment Year :2004-05) & CO No.171/Mum/2010 (Arising out of ITA No.945/Mum/2010 (Assessment Year :2005-06) M/s. Maharashtra State Vs. DCIT – 1(2), Mumbai…

M/S. LUCKY EXPORTS,NEW DELHI vs. DCIT, NEW DELHI

In the result, the appeal filed by the assessee is allowed

ITA 771/DEL/2014[2008-09]Status: DisposedITAT Delhi28 Sept 2020AY 2008-09

Bench: Shri R.K. Panda & Shri Kuldip Singhassessment Year: 2008-09 Lucky Exports, Vs Dcit, Ug-28, Som Dutt Chambers-Ii, Circle-24(1), 9, Bhikaji Cama Place, New Delhi. New Delhi. Pan: Aaafl1147P (Appellant) (Respondent) Assessee By : Shri Naveen N.D. Gupta, Ca Revenue By : Shri Saras Kumar, Sr. Dr Date Of Hearing : 20.08.2020 Date Of Pronouncement : 28.09.2020 Order Per R.K. Panda, Am: This Appeal Filed By The Assessee Is Directed Against The Order Dated 21.11.2013 Of The Cit(A)-28, New Delhi Relating To Assessment Year 2008-09. 2. Facts Of The Case, In Brief, Are That The Assessee Is A Partnership Firm & Is Engaged In The Business As Merchant Exporter. It Filed Its Return Of Income On 27Th September, 2008 Declaring The Total Income At Rs.2,96,21,168/-. During The Course Of Assessment Proceedings, The Ao Observed From The Profit & Loss Account That The Assessee Has Claimed A Sum Of Rs.1,61,35,879/- Under The Head ‘Write Off/Bad Debt.’ He, Therefore, Asked The Assessee To Explain & Justify The Advances /Bad Debt Written Off In Respect Of 22 Parties. He Asked The Assessee To File Partywise Explanation & Justification Of Bad Debt/Advances Written Off & To Produce The Copy Of Account & Names Of Such Parties For The Last Three Years. He Also Asked The Assessee To File: (A) Copy Of Bank Statement When Payment Of Advances Written Off Were Made; (B) Complete Name, Address, Pan & Contact Details Of The Parties Including Current Address, If Any; & (C) Copy Of Correspondence Made In Connection With Recovery Of Loan/Advances Written Off.

For Appellant: Shri Naveen N.D. Gupta, CAFor Respondent: Shri Saras Kumar, Sr. DR
Section 37Section 37(1)

…e assessee would be entitled to the unabsorbed loss in the shape of shares against the income. This was so held by the Supreme Court in Standard Refinery and Distillety Ltd. v. CIT [1971] 79 ITR 589 and again in Produce Exchange Corporation Ltd. v. CIT [1970] 77 ITR 739 (SC). So far as the authorities relied upon by the Revenue are concerned, in all these cases, the criteria adopted by the court was that since the expenditure incurred brought into existence a benefit of enduring nature, it can be treated as capital nature, meaning thereby that depreciation can be claimed upon the total expenditure for setting up…

M/S. VIGNETTE INDIA PVT. LTD.,NEW DELHI vs. DCIT, NEW DELHI

In the result, the appeal of the assessee in ITA No

ITA 980/DEL/2013[2001-02]Status: DisposedITAT Delhi05 Sept 2019AY 2001-02
For Appellant: Sh. Salil Kapoor, AdvFor Respondent: Ms. Naina Soin Kapil, Sr. DR
Section 143(3)

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCHES ‘D’, NEW DELHI Before Sh. Bhavnesh Saini, Judicial Member Dr. B. R. R. Kumar, Accountant Member ITA No. 388/Del/2009 : Asstt. Year : 2001-02 ITA No. 980/Del/2013 : Asstt. Year : 2001-02 M/s Vignette India Pvt. Ltd., Vs Deputy Commissioner of C/o Perfect Accounting and Income Tax, Circle-17(1), Shared Services Pvt. Ltd., E-20, New Delhi-110002 First Floor, Hauz Khas, New Delhi-110016 (APPELLANT) (RESPONDENT) PAN No. AABCV0946J Assessee by : Sh. Salil Kapoor, Adv. Revenue by : Ms. Naina Soin Kapil, Sr. DR Date of Hearing: 13.08.2019 Date of Pronouncement: 05.09.2…

URJA INVESTMENT P. LTD,MUMBAI vs. DCIT 4(2)(1), MUMBAI

In the result, the appeal of the assessee is partly allowed

ITA 3286/MUM/2017[2012-13]Status: DisposedITAT Mumbai26 Jul 2019AY 2012-13

Bench: Shri Mahavir Singh, Jm & Shri M.Balaganesh, Am M/S. Urja Investments Vs. Dy. Commissioner Of Pvt.Ltd Income Tax-4(2)(1) Ground Floor, Khatau Bldg Aayakar Bhavan 8/10, Alkesh Dinesh Mody Mumbai Marg, Fort Mumbai – 400 001 Pan/Gir No.Aaacu0637N (Appellant) .. (Respondent)

Section 143(3)Section 73

…ommon work force and as such bifurcation of such business was not possible. Reliance in this regard was placed on the decision of Hon’ble Supreme Court in the case of Prithvi Insurance Ltd reported in 53 ITR 632 (SC) ; Exchange Corporation Limited reported in 77 ITR 739 (SC). Accordingly, the assessee pleaded that since the assessee is doing composite business, the income therefrom had to be assessed as a whole. Since the share broking activity, share dealing on own account all form an integrated business of the assessee company, the profit or loss from the same is required to be computed as a whole. Hence these…

DIWALI CAPITAL & FINANCE PVT. LTD.,MUMBAI vs. DCIT- CC-2(2), MUMBAI

In the result, the appeals of assessee are partly allowed

ITA 3108/MUM/2018[2014-15]Status: DisposedITAT Mumbai08 May 2019AY 2014-15

Bench: Sri Mahavir Singhaayakr Apila Sam./ Ita No. 3107/Mum/2018 (Inaqa-Arna Baya- / Assessment Year 2013-14) Aayakr Apila Sam./ Ita No. 3108/Mum/2018 (Inaqa-Arna Baya- / Assessment Year 2014-15)

For Appellant: Shri Vimal Punamiya, ARFor Respondent: Shri Satishchandra Rajore, DR
Section 143(3)Section 153ASection 43(5)Section 73

…force as such bifurcation of such business is not possible. In this regard the reference can be made to the decision of the Supreme Court in the case of Prithvi Insurance Ltd reported in 53 ITR page 632 and 637 and in the case of Exchange Corporation Limited 77 ITR 739 (SC) in the case of Exchange Corporation Limited, it was held that the test is unit of control and not the nature of the two line of business. Hon’ble Supreme Court held that the tribunal was right in holding share business and other business carried by the appellant company constituting the same business within the meaning of Section 24(2). As th…

DIWALI CAPITAL & FINANCE PVT. LTD.,MUMBAI vs. DCIT -CC- 2(2), MUMBAI

In the result, the appeals of assessee are partly allowed

ITA 3107/MUM/2018[2013-14]Status: DisposedITAT Mumbai08 May 2019AY 2013-14

Bench: Sri Mahavir Singhaayakr Apila Sam./ Ita No. 3107/Mum/2018 (Inaqa-Arna Baya- / Assessment Year 2013-14) Aayakr Apila Sam./ Ita No. 3108/Mum/2018 (Inaqa-Arna Baya- / Assessment Year 2014-15)

For Appellant: Shri Vimal Punamiya, ARFor Respondent: Shri Satishchandra Rajore, DR
Section 143(3)Section 153ASection 43(5)Section 73

…force as such bifurcation of such business is not possible. In this regard the reference can be made to the decision of the Supreme Court in the case of Prithvi Insurance Ltd reported in 53 ITR page 632 and 637 and in the case of Exchange Corporation Limited 77 ITR 739 (SC) in the case of Exchange Corporation Limited, it was held that the test is unit of control and not the nature of the two line of business. Hon’ble Supreme Court held that the tribunal was right in holding share business and other business carried by the appellant company constituting the same business within the meaning of Section 24(2). As th…

JINDAL STEEL & POWER LTD.,NEW DELHI vs. ACIT, HISAR

In the result, the appeal of the assessee is partly allowed

ITA 893/DEL/2014[2009-10]Status: DisposedITAT Delhi29 Apr 2019AY 2009-10

Bench: Sh. Bhavnesh Saini & Sh. N. S. Sainiita No. 893/Del/2014 : Asstt. Year : 2009-10 Jindal Steel & Power Ltd., Vs Asstt. Commissioner Of Jindal Centre, 12, Bhikaji Cama Income Tax, Hisar Circle, Place, New Delhi-110066 Hisar (Appellant) (Respondent) Pan No. Aaacj7079D Assessee By : Sh. Salil Kapoor, Adv., Sh. Sumit Lal Chandani, Adv., Ms. Ananya Kapoor, Adv. & Ms. Pallavi Saigal, Adv. Revenue By : Sh. Sanjay I. Bara, Cit Dr Date Of Hearing :05.03.2019 Date Of Pronouncement : 29.04.2019 Order Per N. S. Saini: This Is An Appeal Filed By The Assessee Against The Order Of Assessing Officer U/S 143(3)/144C(13) Of The Income Tax Act, 1961 Dated 29.10.2018 For Assessment Years 2013-14

For Appellant: Sh. Salil Kapoor, AdvFor Respondent: Sh. Sanjay I. Bara, CIT DR
Section 143(3)Section 144CSection 80Section 80I

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCHE ‘I-1’, NEW DELHI Before Sh. Bhavnesh Saini, Judicial Member And Sh. N. S. Saini, Accountant Member ITA No. 893/Del/2014 : Asstt. Year : 2009-10 Jindal Steel & Power Ltd., Vs Asstt. Commissioner of Jindal Centre, 12, Bhikaji Cama Income Tax, Hisar Circle, Place, New Delhi-110066 Hisar (APPELLANT) (RESPONDENT) PAN No. AAACJ7079D Assessee by : Sh. Salil Kapoor, Adv., Sh. Sumit Lal Chandani, Adv., Ms. Ananya Kapoor, Adv. & Ms. Pallavi Saigal, Adv. Revenue by : Sh. Sanjay I. Bara, CIT DR Date of Hearing :05.03.2019 Date of Pronouncement : 29.04.2019 ORDER Per N.…

INCOME TAX OFFICER, WARD-2-2, JAIPUR vs. M/S SUKH SAGAR ENCLAVE, JAIPUR

In the result, appeal of the revenue is dismissed

ITA 1116/JPR/2018[2014-15]Status: DisposedITAT Jaipur11 Jan 2019AY 2014-15
For Appellant: Shri P.C. Parwal (C.A)For Respondent: Shri Varinder Mehta (CIT-DR) fu/kZkfjrh dh vksj ls@
Section 37(1)

…straw-board manufacturing factory and the balance sheet represented the financial picture of the company after 14 ITO Vs M/s Sukh Sagar Enclave taking into consideration the affairs of both the units. Relying upon Produce Exchange Corpn. Ltd. v. CIT [1970] 77 ITR 739 (SC), it was held that unity of control is a decisive test and not the nature of the two lines of business. It was further held that if the management, the trading organization, the administration, the funds and the place of business were common, then it cannot be said that the two ventures are two different businesses carried on by the same compa…

GLAXOSMITHKLINE ASIA (P) LTD.,GURGAON vs. ACIT, CHANDIGARH

In the result, appeal of the Assessee is allowed for statistical purposes

ITA 1323/CHANDI/2012[2003-04]Status: DisposedITAT Chandigarh28 Sept 2018AY 2003-04
For Appellant: Sh. Neeraj Jain (C.A), Sh. Abhishek Mukherjee (C.A)For Respondent: Dr. Gulshan Raj
Section 143(3)

…ITR 632 (SC) - Hoogly Trust (P) Ltd. v CIT 73 ITR 685 (SC) - L.M. Chhabda & Sons vs. CIT : 65 ITR 638 (SC) - Standard Refinery & Distillery Ltd. v. CIT: 79 ITR 589 (SC) - B.R. Ltd. v. V.P. Gupta: 113 ITR 647 (SC) - Produce Exchange Corporation Ltd. Vfs. CIT : 77 ITR 739 (SC) In the case of the appellant, aquafresh business is only part of same line of business, which the assessee is already engaged under the control and supervision of the existing management of the company. The aaquafresh toothpaste, in fact, is one of the several products dealt in by the appellant and there is common management, common administ…

HERO MOTOCORP LIMITED,NEW DELHI vs. JCIT, NEW DELHI

In the result appeal of the assessee in ITA No

ITA 1545/DEL/2015[2010-11]Status: DisposedITAT Delhi24 Oct 2016AY 2010-11

Bench: Sh. I. C. Sudhir & Shri Prashant Maharishihero Motocorp Limited, Jcit, 34, Basant Lok, Vasant Range-1, New Delhi Vs. Vihar, New Delhi Pan: Aaach0812J (Appellant) (Respondent) Dcit, M/S. Hero Moto Corp. Circle-11(1), Ltd., 34, Community Vs. New Delhi Centre, Basant Lok, Vasant Vihar, New Delhi-110057 (Appellant) (Respondent) Dcit, M/S. Hero Moto Corp. Circle-11(1), Ltd., 34, Community

For Appellant: Sh. Ajay Vohra, Sr. AdvFor Respondent: Sh. NC Sawain, CIT DR
Section 143Section 143(3)Section 144CSection 92C

…INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ―I-2‖: NEW DELHI BEFORE SH. I. C. SUDHIR, JUDICIAL MEMBER AND SHRI PRASHANT MAHARISHI, ACCOUNTANT MEMBER Hero MotoCorp Limited, JCIT, 34, Basant Lok, Vasant Range-1, New Delhi Vs. Vihar, New Delhi PAN: AAACH0812J (Appellant) (Respondent) DCIT, M/s. Hero Moto Corp. Circle-11(1), Ltd., 34, Community Vs. New Delhi Centre, Basant Lok, Vasant Vihar, New Delhi-110057 (Appellant) (Respondent) DCIT, M/s. Hero Moto Corp. Circle-11(1), Ltd., 34, Community Page 2 of 484 New Delhi Vs. Centre, Basant Lok, Vasant Vihar, New Delhi-110057 (Appellant) (Respondent) M/s. Hero Moto Corp. D…

ITO, WARD-5(4), KOLKATA, KOLKATA vs. M/S. FORTUNE INTERFINANCE LTD., KOLKATA

In the result, the appeal of the Revenue is dismissed

ITA 2064/KOL/2014[2010-2011]Status: DisposedITAT Kolkata05 Aug 2016AY 2010-2011

Bench: Shri P.M. Jagtap

Section 43(5)Section 73

…force as such bifurcation of such business is not possible. In this regard the reference can be made to the decision of the Supreme Court in the case of Prithvi Insurance Ltd reported in 53 ITR page 632 and 637 and in the case of Exchange Corporation Limited 77 ITR 739 (SC) in the case of Exchange Corporation Limited, it was held that the test is unit of control and not the nature of the two line of business. Hon’ble Supreme Court held that the tribunal was right in holding share business and other business carried by the appellant company constituting the same business within the meaning of Section 24(2). As th…

DCIT, CIRCLE - 6,, KOLKATA vs. LOKNATH SARAF SECURITIES LTD.,, KOLKATA

In the result, to sum up ITA No

ITA 852/KOL/2008[2003-04]Status: DisposedITAT Kolkata08 Jul 2016AY 2003-04

Bench: Shri P.M. Jagtap & Shri S.S. Viswanethra Ravi

Section 43(5)Section 73

…force as such bifurcation of such business is not possible. In this regard the reference can be made to the decision of the Supreme Court in the case of Prithvi Insurance Ltd reported in 53 ITR page 632 and 637 and in the case of Exchange Corporation Limited 77 ITR 739 (SC) in the case of Exchange Corporation Limited, it was held that the test is unit of control and not the nature of the two line of business. Hon’ble Supreme Court held that the tribunal was right in holding share business and other business carried by the appellant company constituting the same business within the meaning of Section 24(2). As th…

LOHIA SECURITIES LTD.,KOLKATA vs. DCIT, CIRCLE - 6, KOLKATA, KOLKATA

In the result, the appeal of the assessee is allowed

ITA 487/KOL/2012[2008-2009]Status: DisposedITAT Kolkata09 Dec 2015AY 2008-2009

Bench: : Shri M. Balaganeshita No. 487/Kol/2012 A.Y 2008-09 M/S. Lohia Securities Ltd Vs. Dcit, Circle-6, Kolkata Pan: Aaacl 5834A (Appellant) (Respondent)

For Appellant: Shri Dilip Kumar Patni, CA, ld.ARFor Respondent: Shri G. Mallikarjuna, CIT, ld.DR
Section 143(3)Section 43(5)Section 43(5)(d)Section 73

…force as such bifurcation of such business is not possible. In this regard the reference can be made to the decision of the Supreme Court in the case of Prithvi Insurance Ltd reported in 53 ITR page 632 and 637 and in the case of Exchange Corporation Limited 77 ITR 739 (SC) in the case of Exchange Corporation Limited, it was held that the test is unit of control and not the nature of the two line of business. Hon’ble Supreme Court held that the tribunal was right in holding share business and other business carried by the appellant company constituting the same business within the meaning of Section 24(2). As th…

CIT vs. HINDUSTAN TIMES LTD

Appeal is partly allowed, to the extent it covers the first two questions;

ITA - 95 / 2011HC Delhi14 Sept 2012

…at the proposed insurance business expenditure amounted to expenditure in respect of an existing business. The Tribunal relied upon the judgment reported as CIT v. Tata Chemicals 256 ITR 395; Produce Exchange Corporation Ltd. v. Commissioner of Income-tax 77 ITR 739; Jay Engineering Works Ltd. v. CIT 212 CTR 562 and CIT v. Monnet Industries Limited 221 CTR (Del) 266. The Tribunal, therefore, held that the total amount of ` 43,78,607/- (` 38,01,632- business expenditure and ` 5,76,975/-) paid by the assessee as its share of the joint venture towards proposed insurance business could be properly allowed as…

CIT vs. SONY INDIA PVT LTD

ITA - 1178 / 2011HC Delhi10 Sept 2012
Section 10Section 35D

…ities under the head „business‟. Under Section 70 of the Act, one can set off of loss from one source against income from another source under the same head. In CIT v. Prithvi Insurance Co. (1967) 63 ITR 632 (SC) and Produce Exchange Corporation ltd v. CIT 77 ITR 739 (SC), Supreme Court elucidated upon the said aspect and held that test of “same business” is answered by examining whether there is interconnection, interlacing, inter-dependence and unity of control and 2012:DHC:5578-DB management, common decision mechanism and use of common funds. Once there is interdependence and unity interlacing the bu…

COMMISSIONER OF INCOME TAX vs. DCM LIMITED

In the result the appeal is dismissed

ITA - 987 / 2007HC Delhi13 Jan 2009

…ts and that there were common marketing facilities for all textile units. The Tribunal upon application of the tests laid down by the Supreme Court in the case of CIT vs Prithvi Insurance Co; (1967) 63 ITR 638 and Produce Exchange Corporation Ltd vs CIT; 77 ITR 739 (SC), came to the conclusion that there was inter-connection, inter-lacing and unity of control and management, common decision making mechanism and use of common funds in respect of all four units. It repelled the arguments of the Revenue, which was, once again pressed before us for consideration that, the DCM mill unit was a separate busin…

C.I.T vs. D.C.M. LTD.

In the result the appeal is dismissed

ITA/987/2007HC Delhi13 Jan 2009

…ts and that there were common marketing facilities for all textile units. The Tribunal upon application of the tests laid down by the Supreme Court in the case of CIT vs Prithvi Insurance Co; (1967) 63 ITR 638 and Produce Exchange Corporation Ltd vs CIT; 77 ITR 739 (SC), came to the conclusion that there was inter-connection, inter-lacing and unity of control and management, common decision making mechanism and use of common funds in respect of all four units. It repelled the arguments of the Revenue, which was, once again pressed before us for consideration that, the DCM mill unit was a separate busin…

COMMISSIONER OF INCOME TAX DELHI II vs. MONNET INDUSTRIES LTD.

In the result, the appeal is dismissed

ITA/450/2008HC Delhi21 Nov 2008

Bench: HON'BLE MR. JUSTICE BADAR DURREZ AHMED,HON'BLE MR. JUSTICE RAJIV SHAKDHER

For Respondent: Mr R.D. Jolly
Section 143(1)(a)Section 143(2)Section 260A

…termining whether two lines of businesses constitute the same business and to this end, whether nature of the two businesses has to be looked at, was a proposition, the Supreme Court rejected in the case of a Produce Exchange Corporation Ltd v. CIT: (1970) 77 ITR 739. In this case, the assessee carried on business in diverse commodities as also in stocks and shares. The issue was whether the losses suffered by the assessee in the sale of shares of Public Limited Company could be set off against profits from ITA No. 450/1998 Page 12 of 21 transactions in other commodities in the relevant year…

COMMISSIONER OF INCOME TAX DELHI II vs. MONNET INDUSTRIES LTD.

In the result, the appeal is dismissed

ITA - 450 / 2008HC Delhi21 Nov 2008
For Respondent: Mr R.D. Jolly
Section 143(1)(a)Section 143(2)Section 260A

…termining whether two lines of businesses constitute the same business and to this end, whether nature of the two businesses has to be looked at, was a proposition, the Supreme Court rejected in the case of a Produce Exchange Corporation Ltd v. CIT: (1970) 77 ITR 739. In this case, the assessee carried on business in diverse commodities as also in stocks and shares. The issue was whether the losses suffered by the assessee in the sale of shares of Public Limited Company could be set off against profits from 2008:DHC:3088-DB ITA No. 450/1998 Page 12 of 21 transactions in other commodities in…

Showing 1–20 of 21 · Page 1 of 2

Produce Exchange Corporation Ltd. v. CIT (77 ITR 739) — Cited in 21 Judgments | BharatTax