2018 (5) TMI 1779

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..... he business of the assessee was not on account of speculation. No legal issue arises in such circumstances. Expenditure incurred on account of income which is exempted from tax is not eligible for deduction. Again, on the factual basis, the Appellate Tribunal found that the expenditure claimed as a deduction was not for the purpose of any income which was exempted from tax. Share application .....

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..... rst ground is that the principal income of the respondent assessee is from speculation business and, as such, certain losses could not be set off otherwise than against gains from the same business. It was found, as a matter of fact, that more than 50 per cent of the business of the assessee was not on account of speculation. No legal issue arises in such circumstances. The second ground urged .....

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