Nexus for taxable compensation requires the same loss or deduction; separate receipt for requisitioned premises falls outside section 10(2A).

Compensation for deprivation of the use of requisitioned premises was not assessable as business income under section 10(2A) of the Income-tax Act, 1922 because the statutory condition of identity between the earlier allowance and the later receipt was absent. The earlier deduction had been allowed for rent paid on an alternative godown, while the compensation related to loss of use of the assessee's own Dharmshala. As the two transactions were distinct, the fact that both amounts were calculated at the same monthly rate did not establish the required nexus. The receipt therefore fell outside section 10(2A).

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Issues: Whether compensation received for deprivation of the use of requisitioned premises was assessable as business income under section 10(2A) of the Income-tax Act, 1922.

Analysis: Section 10(2A) applies only where an amount is received in respect of the same loss, expenditure, or trading liability for which an allowance or deduction had earlier been made. The compensation in question was awarded for deprivation of the use of the assessee's own Dharmshala, whereas the earlier allowance had been made in respect of rent paid for an alternative godown taken on hire. The two were distinct transactions, and the coincidence that both amounts were quantified at the same monthly rate did not create the necessary statutory link.

Conclusion: The compensation was not covered by section 10(2A) and was not assessable as income under that provision.

Ratio Decidendi: Section 10(2A) applies only when the later receipt is in respect of the same loss, expenditure, or trading liability for which an earlier deduction was allowed; a separate compensatory receipt, lacking that direct nexus, cannot be deemed business income.

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