SETABGUNJ SUGAR MILLS LTD. vs THE COMMISSIONER OF INCOME-TAX,CENTRAL, CALCUTTA

The Supreme Court held that the determination of whether different ventures by a company constitute one business under Section 24(2) of the Indian Income-tax Act, 1922, is a mixed question of law and fact. The Court emphasized the need to assess interconnection and unity among the ventures, referencing Scales v. George Thompson & Co. Ltd. The High Court was directed to call for a statement of the case from the Tribunal regarding whether the company's activities in sugar manufacturing and jute trading constituted the same business for tax purposes.