9911796707
TMI Blog1971 (3) TMI 38X X X X Extracts X X X X X X X X Extracts X X X X ..... 000 as interest - Tribunal has specifically held that the activities at Barabanki and Lahore were quite diverse and distinct and there was no interconnection, interlacing or interdependence between the two businesses - Since the businesses were held to be separate and there was no interconnection, the interest paid on liability of the other business which was transferred to the second business cou ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... amounted to Rs. 7,51,397. For the assessment year 1949-50 the assessee claimed a deduction on account of interest paid in respect of these liabilities. The claim was disallowed by the Income-tax Officer on the ground that the liabilities related to the defunct business in Pakistan. He estimated the interest at Rs. 40,000 and added that amount to the profits. Similarly, for the assessment year 1951 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... been received. The Tribunal has clearly found that the flour mill at Lahore was a separate business from the sugar mill at Barabanki. It has specifically held that the activities at Barabanki and Lahore were quite diverse and distinct and there was no interconnection, interlacing or interdependence between the two businesses. Learned counsel for the assessee has referred us to the decision of the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... , and in the absence of anything to show that the finding is erroneous in law, we must take it as the basis for deciding the question referred. It seems to us that there can be no dispute that upon that finding the question referred must be answered in the negative. The question is answered in the negative in favour of the Commissioner of Income-tax and against the assessee. The Commissioner is e ..... X X X X Extracts X X X X X X X X Extracts X X X X
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