9911796707
TMI Blog1970 (5) TMI 4X X X X Extracts X X X X X X X X Extracts X X X X ..... nter-lacing, inter-dependence and unity furnished by the existence of common management, common business organisation, common administration, common fund and a common place of business - - - - - Dated:- 6-5-1970 - Judge(s) : K. S. HEGDE., J. C. SHAH. and A. N. GROVER. JUDGMENT The judgment of the court was delivered by SHAH J.-- The Income-tax Appellate Tribunal referred the follow ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Tribunal is incomplete and has omitted to state material facts bearing upon the question referred. For instance, it is not clear as to whether the assessee adduced any evidence as to why it started purchasing the shares of the lessor company about six months after the commencement of the lease. It is also not stated by the Tribunal whether there is any evidence of inter-relation between the purch ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... sor company ? 6. For what reason was the entire block of shares sold in April, 1947, to the Produce Exchange Corporation ? " The Tribunal has submitted a supplementary statement of the case and has annexed thereto the articles of association of the assessee. Even after considering those findings, we find ourselves unable to record our opinion on the question referred. We may observe that the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... -dependence and unity furnished by the existence of common management, common business organisation, common administration, common fund and a common place of business. In the present case the statement of the case does not refer to the evidence relating to the existence or otherwise of inter-connection, inter-lacing or interdependence between the two lines of business. There is no reference to ..... X X X X Extracts X X X X X X X X Extracts X X X X
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