https://www.taxtmi.com/caselaws?id=6320 For section 23A of the Indian Income-tax Act, 1922, the controlling test was whether dealing in or holding investments formed the company's primary business. A company with more than one substantial activity will not fall within the provision unless investment dealing is its dominant activity. Shares acquired to safeguard and support a managing agency business were treated as connected to that business, not as evidence of a separate investment business. On the company's objects, profits, and assets employed, the business was not predominantly in investments, so section 23A did not apply and the Revenue's contention failed. en-us Thu, 16 Sep 1971 00:00:00 +0530 Wed, 29 Jun 2016 15:45:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=6320 For section 23A of the Indian Income-tax Act, 1922, the controlling test was whether dealing in or holding investments formed the company's primary business. A company with more than one substantial activity will not fall within the provision unless investment dealing is its dominant activity. Shares acquired to safeguard and support a managing agency business were treated as connected to that business, not as evidence of a separate investment business. On the company's objects, profits, and assets employed, the business was not predominantly in investments, so section 23A did not apply and the Revenue's contention failed. Case-Laws Income Tax Thu, 16 Sep 1971 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=6320