https://www.taxtmi.com/caselaws?id=5056 Income from Government securities held by a co-operative society whose business income was exempt had to be segregated between business and non-business components. In the absence of any operative statutory rule or departmental direction, apportionment was required on commercial accounting principles. The Explanation to section 8 of the Indian Income-tax Act, 1922 applied only to banking companies and could not govern the society. The correct basis was the proportion that capital employed for the business bore to total working capital, not the artificial allocation method in the Explanation. On that basis, only the apportioned amount was taxable, and the assessee's appeal succeeded. en-us Wed, 19 Jul 1967 00:00:00 +0530 Sat, 04 Jun 2016 12:27:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=5056 Income from Government securities held by a co-operative society whose business income was exempt had to be segregated between business and non-business components. In the absence of any operative statutory rule or departmental direction, apportionment was required on commercial accounting principles. The Explanation to section 8 of the Indian Income-tax Act, 1922 applied only to banking companies and could not govern the society. The correct basis was the proportion that capital employed for the business bore to total working capital, not the artificial allocation method in the Explanation. On that basis, only the apportioned amount was taxable, and the assessee's appeal succeeded. Case-Laws Income Tax Wed, 19 Jul 1967 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=5056