INDORE MALWA UNITED MILLS LTD. vs THE COMMISSIONER OF INCOME-TAX(CENTRAL) BOMBAY

The Supreme Court held that under Section 24 of the Indian Income-tax Act, 1922, the term 'profits or gains' refers specifically to taxable profits or gains, excluding income from non-taxable territories for non-residents. The Court affirmed the High Court's decision that the losses incurred in the assessment year 1948-49 could not be set off against profits from subsequent years as they did not meet the criteria established in Section 24(1) and related provisions. Consequently, the appeal was dismissed, upholding the High Court's ruling.