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Satya Narain Bagla vs Commissioner Of Income-Tax, U. P. ... on 8 November, 1966

In Satya Narain Bagla v. Commissioner of Income-tax, [1968] 67 I.T.R. 240 (All.) it was held that it is no doubt true that for a separate source of income, an option of a different previous year can be exercised, and the condition with which compliance is necessary to entitle the exercise of such option is that separate accounts for that particular source should have been maintained for such year. In the present case, the accounts had been made up to a date other than the 31 st day of March (those had been made in the present case up to the 31st of August, 1953), and the assessee could opt for a previous year other than the financial year in respect of the income in question. We have no hesitation in holding that for entitling an assessee to exercise an option under Sub-clause (a) of Clause (i) of Sub-section (11) of Section 2 of the Act, in respect of any separate source of income, it is not necessary for him to have either a separate book of account in respect of the income from the separate source or even to have a separate part of the book confined to income from that source. It is enough if account in respect of the separate source of income has been maintained by the assessee, and that account has been made up to a date within the twelve months ending on the 31st day of March next preceding the year for which assessment is to be made in respect of a year ending on any date other than the 31st day of March, to entitle an assessee to exercise the option in question for the first time in respect of the separate source.
Allahabad High Court Cites 18 - Cited by 3 - Full Document

Shri Sobhag Mal Lodha vs Commissioner Of Income-Tax, Delhi. on 17 May, 1966

In Sobhag Mal Lodha's case, a Division Bench of the Allahabad High Court held that within the same head of income, there can be various sources, and Section 2(11) defines the "previous year" with reference to sources of income and not heads of income. There is no quarrel with that proposition of law, but it does not help in deciding the matter before us. The Allahabad High Court further held in that case that, even under the same head, there can be two sources, each of which would provide a different source of income ; and it is always open to an assessee to have one previous year for one source of business income, and another previous year for the second source of business income, even though both the sources may fall under the same head, i.e., "business". In the present case, there is no dispute about the fact that the source of dividend income was separate from the source of the other income of the assessee.
Allahabad High Court Cites 6 - Cited by 5 - Full Document

Hukam Chand Ulfatrai vs Commissioner Of Income-Tax Delhi. on 13 October, 1966

As held by a Division Bench of this court sitting in circuit at Delhi, to which judgment I was a party, in Hukam Chand Ulfatrai v. Commissioner of Income-tax, [1967] 64 I.T.R. 619 (Punj.) there can be no previous year in respect of income from an undisclosed source other than the financial year next preceding the assessment year. Cases relating to income from undisclosed sources do not, therefore furnish any analogy to cases of the present type.
Punjab-Haryana High Court Cites 8 - Cited by 3 - Full Document
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