Same business test fails where two activities lack interconnection, common management and interdependence; interest deduction denied.

A business connection claim failed because the assessee's Lahore flour mill and Barabanki sugar mill were found to be distinct commercial activities, with no interconnection, interlacing or interdependence and none of the usual indicia of unity such as common management, common organisation, common administration, common fund or a common place of business. The Tribunal's finding that the two operations were separate was a finding of fact, and no legal error was shown in it. On that basis, the activities were not treated as the same business for tax deduction purposes, and interest on the transferred liabilities was not allowable.

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Issues: Whether the assessee's Lahore flour mill and Barabanki sugar mill constituted the same business so as to justify allowance of interest on the transferred liabilities.

Analysis: The Tribunal found that the Lahore and Barabanki activities were distinct and diverse, with no interconnection, interlacing or interdependence between them. The indicia of a single business identified in the governing test, such as common management, common organisation, common administration, common fund and common place of business, were absent. That finding was one of fact and no legal error in it was shown.

Conclusion: The business at Lahore and Barabanki did not constitute the same business, and the claimed interest deduction was not allowable.

Ratio Decidendi: Where the factual finding is that two commercial activities are distinct and lack interconnection, interlacing, interdependence and the usual indicia of unity, they cannot be treated as the same business for tax deduction purposes.

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