Jobbing activity is speculative u/s 43(5)(c) unless otherwise proven; distinct business per section 28 Explanation 2.

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....Jobbing Activity - where and to the extent the assessee is unable to establish its jobbing activity as falling within the purview of s. 43(5)(c), the same, whether finally resulting in a profit or loss, being speculative by definition, would qualify as a separate and distinct business activity in terms of Explanation 2 to section 28 of the Act. - AT....