https://www.taxtmi.com/caselaws?id=37310 For section 23A of the Indian Income-tax Act, 1922, the controlling enquiry is whether a company carries on a real, substantial and organised activity in investments as its primary business. "Investment" is not confined to a technical sense and may include deposits made to earn income where they form part of the company's systematic profit-making activity. On the facts, the assessee derived income from shareholdings and regular deposits of surplus funds with allied concerns, and that activity was held to be its main business. The company was therefore treated as one whose business consisted wholly or mainly in dealing in or holding investments, and the higher statutory percentage applied. en-us Fri, 09 Mar 1979 00:00:00 +0530 Mon, 29 Mar 2010 10:27:34 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=37310 For section 23A of the Indian Income-tax Act, 1922, the controlling enquiry is whether a company carries on a real, substantial and organised activity in investments as its primary business. "Investment" is not confined to a technical sense and may include deposits made to earn income where they form part of the company's systematic profit-making activity. On the facts, the assessee derived income from shareholdings and regular deposits of surplus funds with allied concerns, and that activity was held to be its main business. The company was therefore treated as one whose business consisted wholly or mainly in dealing in or holding investments, and the higher statutory percentage applied. Case-Laws Income Tax Fri, 09 Mar 1979 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=37310