AMALGAMATIONS P LIMITED Vs. COMMISSIONER OF INCOME TAX

JUDGEMENT

(1.) THE facts in this reference are the same and the questions are :

(2.) SO far as the third question is concerned, counsel for the assessee, at whose instance this reference has been made, does not press it. It is, therefore, not necessary to answer this question. As regards the first two questions, they turn on the propriety of including the two sums in the computation of commercial profits for the purpose of Section 23A. SO far as the loss claimed on account of the farm said to be conducted by the assessee is concerned, there are no facts before us to conclude that this is a legitimately permitted business loss. We do not even know whether the farm is within the objects of the assessee-company. In such circumstances, we are of opinion that the Tribunal was right in taking this amount into account in computing the commercial profits.