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    <title>1971 (2) TMI 27 - CALCUTTA High Court</title>
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    <description>For section 23A of the Indian Income-tax Act, 1922, &quot;investment&quot; was construed in its ordinary commercial sense, not as a term of art. Income-yielding immovable property, including houses let for rent, could constitute investments where the company&#039;s objects and main income showed that such properties formed its principal business. Classification of that income under section 9 did not change the character of the underlying assets, because the Act&#039;s heads of income are only a mode of computation. On that basis, the company was treated as one whose business consisted mainly in holding investments, and the departmental position was sustained.</description>
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    <pubDate>Tue, 09 Feb 1971 00:00:00 +0530</pubDate>
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      <title>1971 (2) TMI 27 - CALCUTTA High Court</title>
      <link>https://www.taxtmi.com/caselaws?id=8457</link>
      <description>For section 23A of the Indian Income-tax Act, 1922, &quot;investment&quot; was construed in its ordinary commercial sense, not as a term of art. Income-yielding immovable property, including houses let for rent, could constitute investments where the company&#039;s objects and main income showed that such properties formed its principal business. Classification of that income under section 9 did not change the character of the underlying assets, because the Act&#039;s heads of income are only a mode of computation. On that basis, the company was treated as one whose business consisted mainly in holding investments, and the departmental position was sustained.</description>
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      <pubDate>Tue, 09 Feb 1971 00:00:00 +0530</pubDate>
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