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Issues:
1. Computation of income under different heads for assessment years 1977-78 and 1978-79. 2. Inclusion of income from a specific property in the total income. 3. Classification of interest income, guarantee commission, profits on sale of assets, and miscellaneous income under the head "Business." 4. Deductibility of interest on fixed deposits for estate duty payment. 5. Set off of carried forward losses against current year's income. 6. Assessment of interest on investments under the head "Business." 7. Allowance of credit guarantee paid for estate duty payment as a deduction. 8. Grossing up of foreign dividend for income-tax purposes. Analysis: 1. The first issue pertains to whether the income should be computed under the head "Business" or other sources. Previous judgments have established that systematic investment activities constitute a business. Hence, income from property and other sources should also be included in the business income. 2. The second issue involves the computation of income from a specific property for inclusion in the total income. Previous decisions have upheld the inclusion of such income in the total income, supporting the current stance. 3. The third issue concerns the classification of various incomes under the head "Business." Previous judgments have determined that interest income and other related earnings should be considered as falling under the business income category. 4. The fourth issue addresses the deductibility of interest on fixed deposits for estate duty payment. Precedents indicate that such interest should be allowed as a deduction. 5. The fifth issue revolves around the set off of carried forward losses against the current year's income. Previous rulings have favored allowing such set-offs, supporting the taxpayer's position. 6. The sixth issue pertains to the assessment of interest on investments under the head "Business." Earlier decisions have established that interest receivable on investments should be assessable as business income. 7. The seventh issue involves the allowance of credit guarantee paid for estate duty payment as a deduction. Prior judgments have supported the deduction of such expenses. 8. The final issue concerns the grossing up of foreign dividends for income-tax purposes. The court held that the gross dividend alone should be considered for taxation, contrary to the Tribunal's decision. In conclusion, the court answered questions 1 to 7 in favor of the assessee and against the Department. However, question 8 was answered in favor of the Department. No costs were awarded in this judgment.
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