https://www.taxtmi.com/caselaws?id=292471 Relief under section 25 of the Income-tax Act, 1922 was available only if the same business, profession or vocation had in fact been charged to tax under the Income-tax Act, 1918. On the facts stated, the assessee had been assessed under the 1918 Act only on interest from investment of surplus capital, not on the railway business itself. Income taxed as "interest on securities" could not be recharacterised as business income merely because the investments were authorised or connected with the company's objects. As the railway business had not commenced during the relevant period, no tax had been charged on that business within section 25, and relief under section 25(3) or section 25(4) was unavailable. en-us Tue, 22 May 1945 00:00:00 +0630 Fri, 25 Dec 2020 09:58:23 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=292471 Relief under section 25 of the Income-tax Act, 1922 was available only if the same business, profession or vocation had in fact been charged to tax under the Income-tax Act, 1918. On the facts stated, the assessee had been assessed under the 1918 Act only on interest from investment of surplus capital, not on the railway business itself. Income taxed as "interest on securities" could not be recharacterised as business income merely because the investments were authorised or connected with the company's objects. As the railway business had not commenced during the relevant period, no tax had been charged on that business within section 25, and relief under section 25(3) or section 25(4) was unavailable. Case-Laws Income Tax Tue, 22 May 1945 00:00:00 +0630 https://www.taxtmi.com/caselaws?id=292471