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General Commercial Corporation Ltd. vs Commissioner Of Income-Tax, Madras. on 30 April, 1964

The only factor that has been taken against the assessee having continued its business of financing, other than banking, is the fact that it advanced no loan to anybody until some time, in September, 1952, but mere inactivity for a period does not mean that its business ceased to exist or that it did not carry on business at all. A business may be inactive for a period and merely because of the dormancy of the business, the conclusion that it has ceased does not arise. . This is the view that has prevailed in General Corporation Ltd. v. Commissioner of Income-
Madras High Court Cites 15 - Cited by 10 - Full Document

Inderchand Hari Ram vs Commissioner Of Income-Tax And C.P. & ... on 4 March, 1952

tax, [1935] 3 I.T.R. 350,. 355 and Inderchand Hari Ram v. Commissioner of Income-tax, . [1953] 23 I.T.R. 437, 442. Another matter that has been referred to in this connection is the resolution passed by the assessee on March 10, 1951--. "Resolved that the company do continue and carry on such business for one or the other of its objects as mentioned in the memorandum of association of the company as may be decided upon by the board of directors, from time to time. " The contention in this respect has been that the board of directors never took decision to continue the remaining part of the financing business by the assessee after it had dropped its banking business. The Tribunal rightly pointed out that the memorandum of association had many objects in it covering almost the whole of the field under Section 277F of the Indian Companies Act, 1913, and, of course under Section 6 of Act 10 of ,1949. The assessee was not embarking on the business of all the objects at once. The resolution was meant to cover such of the objects with which the assessee was not immediately dealing so as to empower the directors to develop its business further with regard to those objects. This resolution cannot possibly be interpreted to mean that the assessee put a stop to its whole business on March 10, 1951, leaving it to a resolution of the directors to start it over again. The consequence is that the Tribunal had material before it on which it could hold that the assessee had carried on the business of financing and money-lending after March 10, 1951, and the answer to the first question is in the affirmative, ,
Allahabad High Court Cites 16 - Cited by 35 - V Bhargava - Full Document
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