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3. The Income-tax Officer took the view that since the business of purchase and sale of National Defence Remittance Scheme Certificates, hereinafter referred to as "Certificates", was not carried on in the assessment year in question, the assessee was not entitled to carry forward and set off the unabsorbed loss under section 72(1) of the Income-tax Act, 1961. The Appellate Assistant Commissioner took the view that the transactions had been entered in a single set of account books and that the funds required for the two items of activities had also been shown to be from a common source both in the account books and also in the bank accounts maintained by the assessee and, therefore, there had been unity of control and management in respect of these two activities.

5. Mr. Jayaraman, on behalf of the Revenue, has, with regard to question No. 1, contended that the business of distribution of cinema films and the business of "National Defence Remittance Scheme Certificates", cannot be treated as one and the same business and according to him, the closure of any one of these activities could not affect the carrying on of the other business activity. Learned counsel argued that the interdependence of the several activities cannot be determined merely with reference to the financial aspect and notwithstanding that funds for both the business activities came from a common source, if the distribution of films activity could be carried on even though the business activity of purchase and sale of "Certificates" was discontinued, it clearly indicates, according to learned counsel, that there was no interdependence between the two activities. Learned counsel pointed out that the decisions on which the Tribunal has relied on were decisions given in the case of companies which were the assessees, but the assessee in the present case was an individual. In such a case, according to learned counsel, funds for the two different kinds of activities were bound to come from a common source and, consequently, the test of interlacing and interdependence must be determined with reference to the possibility of one activity being carried on with or without the aid of the other activity.