TMI Blog1969 (2) TMI 41X X X X Extracts X X X X X X X X Extracts X X X X ..... 53-1954. The assessee was a partnership in that year, the terms of it reduced to a writing dated September 22, 1944. It had two items of business, one S.V.O.C. agency under the firm name Tinnevelly I. S. C. Machado, Tinnevelly, and the other in country craft route agency. It appears that the firm was entrusted with a consignment of rice for transport from Trivandrum to Tuticorin. But the country ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... incurred in respect of any agency business carried on during the assessment year, and that the expenditure incurred could not be deducted from or taken into account in ascertaining the profits of the other business. The question before us is : " Whether, on the facts and in the circumstances of the case, the assessee-firm is not entitled to the deduction of the sum of Rs. 31,820 as an admissibl ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... had ceased to exist. If the income of a business is not taxable under section 10 as income of a particular year because the business was not carried on in that year, the assessee can obviously not seek to debit the expenditure incurred for carrying on that business, against his other income, for the outgoings are chargeable only against the income of a business which was carried on in the previou ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... of a distinct nature, each has got to be taken as a separate unit for purposes of ascertainment of profits. Expenditure under section 10(1) is allowed not as a deduction or as allowance but as the component inherent in the process of ascertaining the profits, namely, arriving at the net result of credits and debits referable to a particular independent activity of business. The expenditure should ..... X X X X Extracts X X X X X X X X Extracts X X X X
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