Dismissing the appeal of the revenue , the Court held that , where investments were business investments, carried forward business loss could be set off against dividend income earned from such business investment as even though dividend was classified under separate head, but same was very much part of income from business. Followed United Commercial Bank Ltd v. CIT ( 1957) 32 ITR 688 (SC) , CIT v. Cocanada Radhaswami Bank Ltd ( 1965) 57 ITR 306 (SC). (AY. 1997-98)
CIT v. Shriram Chits & Investments (P.) Ltd. (2018) 257 Taxman 395/(2019) 410 ITR 10 (Mad.)(HC)
S. 72 : Carry forward and set off of business losses – Dividend – where investments were business investments, carried forward business loss could be set off against dividend income earned from such business investment as even though dividend was classified under separate head, but same was very much part of income from business.[ S.56 ]