https://www.taxtmi.com/caselaws?id=37275 Commercial profits under section 23A of the Indian Income-tax Act, 1922 must be determined on broad commercial principles, not by treating every assessment disallowance as real profit. Only additions that genuinely reflect suppressed income or inflated expenditure can be regarded as distributable commercial profits. A mere disallowance of a claimed loss does not, by itself, prove that the disallowed amount was available for distribution. Because the primary facts needed to decide whether the claimed losses were true commercial losses or profits were not fully found, the issue had to be reconsidered on a proper factual basis. en-us Thu, 26 Feb 1976 00:00:00 +0530 Sat, 27 Mar 2010 17:13:07 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=37275 Commercial profits under section 23A of the Indian Income-tax Act, 1922 must be determined on broad commercial principles, not by treating every assessment disallowance as real profit. Only additions that genuinely reflect suppressed income or inflated expenditure can be regarded as distributable commercial profits. A mere disallowance of a claimed loss does not, by itself, prove that the disallowed amount was available for distribution. Because the primary facts needed to decide whether the claimed losses were true commercial losses or profits were not fully found, the issue had to be reconsidered on a proper factual basis. Case-Laws Income Tax Thu, 26 Feb 1976 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=37275