Allowing the appeal of the assessee the Court held that ; Once cash advances was assessed as business income the same has to be taken in to consideration for the purpose of book profit . It was not open to the Department to contend that the amount of Rs. 1,55,289 was part of business income while computing the tax payable but not so for the purposes of section 40(b) of the Act. The character of the income would not change depending upon the section to be applied.