SAIT NAGJEE PURUSHOTHAM AND CO. vs COMMISSIONER OF INCOME-TAX, MADRAS

The Supreme Court ruled that under Section 25(4) of the Income Tax Act, 1922, a firm cannot claim tax relief if it has discontinued its business prior to the relevant date. The Court found that the original firm had ceased operations in October/November 1937 and had split into two separate partnerships, thus disqualifying the successor firm from relief under the Act. Consequently, the appeal for tax relief for the assessment years 1948-49 and 1949-50 was denied.