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Documents citing Anglo-French Textile Co. Ltd vs Commissioner Of Income-Tax, Madras on 22 December, 1952

The Anglo-French Textile Company Ltd. vs Commissioner Of Income-Tax, Madras on 8 December, 1953

36. and remanded the case to the High Court with the direction that it should give its opinion on these two questions. The High Court has accordingly considered these two questions which were referred to it for opinion and has answered Question No. 1 in the negative and against the assessee and Question. No 2 in the manner following, i.e., the income received in British India cannot be said to wholly arise in India within the meaning of Section 4A(c)(b) of the Act and that there should be allocation of the income between the various profit producing operations of the business of the company the light of the principle contained in the judgments in Ahmedbhai Umarbhai's case and in Anglo-French Textile Company v. Income-tax Commissioner relating to the same assessee.
Supreme Court of India Cites 26 - Cited by 132 - Full Document

United Commercial Bank Ltd. vs The Commr. Of Income-Tax, West Bengal on 18 May, 1953

25. Towards the end of his argument, I pointed out to Mr. Chaudhuri that there was a special difficulty in his way which he might consider. His client was claiming to be allowed to set off the business loss of Rs. 3,21,929/-brought forward from the preceding year against the interest on securities of the present assessment year. That he could do only under Section 24 (2) of the Act, but that section, as recently interpreted by the Supreme Court in -- 'Anglo-French Textile Co., Ltd. v. Commissioner of Income-tax, Madras' AIR 1953 SC 111 (L), required that the income which had been carried over and which was intended to be set off against the present year's business income, must be such as had been set off under another head of income in the year from which it was being carried forward. Their Lordships pointed out that under Section 24 (1) of the Act, loss under any of the heads mentioned in Section 6 is to be set off against income, profits or gains under any other head. Under Section 24 (2), it is only the portion "not so set off" which can be carried forward.
Calcutta High Court Cites 18 - Cited by 1 - Full Document

Commr. Of Income-Tax, Punjab, Pepsu, ... vs Hira Mall Narain Dass on 22 June, 1953

6. Their Lordships of the Supreme Court in -- 'the Anglo French Textile Co. Ltd. v. Commr. of Income-tax, Madras', AIR 1953 SC 111 (D), have held (and I give the head note) that a set off under Section 24(1), Income-tax Act can only be claimed when the loss arises under one head and the profit against which it is sought to be set off arises under a different head. When the two arise under the same head the loss can be deducted but that is done under Section 10 and not under Section 24(1), Income-tax Act.
Punjab-Haryana High Court Cites 24 - Cited by 13 - Full Document
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