https://www.taxtmi.com/caselaws?id=9058 Capital gains, being assessable income under the Indian Income-tax Act, 1922, could be deducted in computing business loss to be carried forward under section 24(1), because set-off is permitted against other assessable income. By contrast, dividend income from a Pakistan company that was taxed in Pakistan and not chargeable in India under the double-taxation agreement could not be reduced from the Indian business loss, since loss under section 24 can be adjusted only against income assessable in India and the agreement cannot be defeated by indirect taxation through loss computation. The net effect was that assessable capital gains reduced the carry-forward loss, but exempt foreign dividend income did not. en-us Fri, 19 Oct 1973 00:00:00 +0530 Thu, 18 Jun 2009 19:31:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=9058 Capital gains, being assessable income under the Indian Income-tax Act, 1922, could be deducted in computing business loss to be carried forward under section 24(1), because set-off is permitted against other assessable income. By contrast, dividend income from a Pakistan company that was taxed in Pakistan and not chargeable in India under the double-taxation agreement could not be reduced from the Indian business loss, since loss under section 24 can be adjusted only against income assessable in India and the agreement cannot be defeated by indirect taxation through loss computation. The net effect was that assessable capital gains reduced the carry-forward loss, but exempt foreign dividend income did not. Case-Laws Income Tax Fri, 19 Oct 1973 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=9058