Business-specific tax relief under Section 25(4) applies only to the successor business, not to separate undertakings.

Section 25(4) relief was construed as confined to the particular business that had been assessed under the earlier Act and then succeeded to in the same capacity. Read with Section 25(3) and the super-tax proviso, the phrase "income, profits and gains" was held to refer to the income of that business, profession or vocation, not to the assessee's total income from all sources. The provision was intended to prevent double taxation of the same business only. Accordingly, where an assessee carried on distinct businesses, the relief could not extend to businesses not previously assessed under the earlier regime or not shown to form part of the same business.

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Issues: Whether the relief under Section 25(4) of the Income-tax Act was confined to the particular business that had been assessed to tax under the earlier Act and succeeded to by another person, or whether it extended to the assessee's total income and other distinct businesses.

Analysis: Section 25(4) was construed in the setting of Section 25(3) and the proviso dealing with super-tax, showing that the expression "income, profits and gains" was used in relation to the business, profession or vocation described in Section 10 and not to the assessee's entire income from all sources. The relief was intended to prevent double taxation of the same business which had already borne tax under the earlier regime and was thereafter succeeded to in the same capacity. Where the assessee carried on several distinct businesses, the benefit could not be extended to businesses that were neither assessed under the earlier Act nor shown to be part of the same business.

Conclusion: The relief under Section 25(4) was available only in respect of the money-lending business that had been assessed under the earlier Act, and not in respect of the separate ginning factory and share businesses.

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