TaxTMI 
TaxTMI 
1975 (11) TMI 3
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....Act of 1961 (hereinafter referred to as " the Act "), the Income-tax Appellate Tribunal has stated this case and referred the following question for opinion of the court : Whether, on the facts and in the circumstances of the case, the loss of Rs. 27,420 sustained by the assessee on sale of Government Loan Bonds is capital loss or revenue loss ? The assessee is a private limited company and ....
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....iled to satisfy the ITO that the purchase of the Government Loan Bonds was a condition to securing purchase orders from the State Government. It was further found that the assessee was not dealing in Government Bonds and did not have any stock-in-trade. Accordingly he came to the conclusion that the investment was of capital nature and loss therein could not be treated as revenue expenditure for c....
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....qual sum. This leaves no room for any suspicion that the business secured by the assessee was as a result of purchase of the securities and, therefore, direct nexus has been established. In this view of the matter, the addition is deleted as business expenditure." Reliance has been placed by learned standing counsel on a decision of this court in the case of CIT v. Patnaik and Co. (P.) Ltd. [19....
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....d appear from the appellate order of the Tribunal. There is a further finding that business was secured contemporaneously from the very department. This is not a case where the assessee claims that the loan bonds were purchased for any enduring return. On the other hand, the finding is that there is a boosting up in the business in the year itself. The link which was wanting in the reported decisi....