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    <title>1967 (2) TMI 17 - DELHI High Court</title>
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    <description>Losses from earlier years could be carried forward and set off where the later profits arose from the same business activity. The controlling test under section 24(2) of the Indian Income-tax Act, 1922 was whether the earlier individual liquor contracts and the later partnership liquor contract constituted the same business. The court treated the change from carrying on the activity individually to earning profits through a registered firm as immaterial, because the nature of the business remained liquor contracting. The distinction between assessment of a partner in a registered firm and in an unregistered firm affected tax computation and collection, but not business identity. The earlier losses were therefore available for set-off against the assessee&#039;s share of firm income.</description>
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    <pubDate>Fri, 24 Feb 1967 00:00:00 +0530</pubDate>
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      <title>1967 (2) TMI 17 - DELHI High Court</title>
      <link>https://www.taxtmi.com/caselaws?id=6906</link>
      <description>Losses from earlier years could be carried forward and set off where the later profits arose from the same business activity. The controlling test under section 24(2) of the Indian Income-tax Act, 1922 was whether the earlier individual liquor contracts and the later partnership liquor contract constituted the same business. The court treated the change from carrying on the activity individually to earning profits through a registered firm as immaterial, because the nature of the business remained liquor contracting. The distinction between assessment of a partner in a registered firm and in an unregistered firm affected tax computation and collection, but not business identity. The earlier losses were therefore available for set-off against the assessee&#039;s share of firm income.</description>
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      <pubDate>Fri, 24 Feb 1967 00:00:00 +0530</pubDate>
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