under the head "profits and gains of business,
profession or vocation" under s. 10 and that therefore, the
respondent was not entitled ... enacts that "where any business, profession or vocation on
which tax was at any time charged, it is intended that
Profits and gains of
business, profession or vocation" and the fifth head "income
from other sources". The fifth head is the residuary ... fourth head, viz.,
"Profits and gains of business, profession or vocation".
They were not, however, chargeable to tax under that head
because under
following terms :
"Whether any business, profession or vocation on which tax was at any time charged under the provisions of the Indian Income ... section (3), of providing that where a business, profession or vocation was discontinued, no tax shall be payable in respect of the period between
horses and betting on horses of others as a regular business or vocation which he has been conducting for a number of years ... support of his view that horse racing cannot be called either a vocation, business or profession. It is unnecessary for us in this case
being receipts arising from business or the exercise of a profession, vocation or occupation, which are of a casual and non-recurring nature ... receipts arising "from business or the exercise of a profession, vocation or occupation" as held by Rowlatt J. in the decision quoted above
portion thereof occupied for the purpose of "any business, profession or vocation carried on" by the assessee "the profits of which were ... whether the assessee was carrying on any such "business, profession or vocation....... the profits of which are assessable to tax," as entitle
succeeded to the business and the vocation carried on by him, she was entitled to the relief under Section ... assessee were not, in reality, the assets of the business or vocation carried on by him. He agreed with the Income-tax Officer that relief
assessee under the head 'Profits and gains of business, profession or vocation' in respect of the profits or gains of any business, profession ... vocation carried on by him."
And Section 24(1) , at the relevant time, declared;
"24 (1). Where any assessee sustains a loss
After retirement he had also no whole time profession, vocation or occupation, when he was leading the life of a pensioner. In September 1941, some ... being receipts arising from business or the exercise of a profession, vocation or occupation, which are of a casual and non-recurring nature
Income from property
(iv) Profits and gains of business, profession or vocation.
(v) Income from other sources.
(vi) Capital gains.
The subsequent sections contain ... Section 10 dealing with profits and gains arising from business, profession or vocation.
(5) These sections are contained in Chapter III of the Act dealing