Single business test depends on interdependence and nexus, not just common management or shared head office arrangements.

Whether tea, coffee and fertiliser ventures formed one business turned on interconnection, interlacing, interdependence and unity of control, not on common management or common accounting alone. The Court noted that shared administration, common funds and a common head office were relevant, but insufficient by themselves to establish a single integrated business. On the facts, fertiliser manufacture had a distinct commercial character and no real nexus with the tea and coffee operations, while the coffee activity also remained separately identifiable. As a result, the ventures were treated as separate businesses for deduction purposes, and full set-off of managing agency commission, sitting fees and head office expenses was not available across all activities.

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Issues: Whether the assessee's tea, coffee and fertiliser activities constituted a single and unitary business so as to permit full deduction of managing agency commission, sitting fees and head office expenses against the aggregate income.

Analysis: The decisive inquiry was not unity of control alone, but whether the activities were interlinked in the sense of interconnection, interlacing and interdependence. The common management, common administration, common funds and common head office were relevant, but they were insufficient by themselves. Applying the objective tests for determining whether different activities form one business, the Court found that the fertiliser manufacture had a distinct commercial character and no real nexus with the tea and coffee business. The coffee activity also remained separately identifiable, and the mere fact that all receipts and expenses were routed through the head office did not convert the different ventures into one integrated business.

Conclusion: The assessee's tea, coffee and fertiliser activities were not a single business; the deductions claimed had to be confined to the taxable business activities and could not be allowed in relation to the coffee business.

Ratio Decidendi: Whether several activities constitute one business depends on the presence of interconnection, interlacing, interdependence and unity of control, and common management or common accounting alone is not conclusive.

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