AMARCHAND SOBHACHAND vs COMMISSIONER OF INCOME TAX, MADRAS

The Supreme Court held that under Section 10(2)(vi) and Section 66(1) of the Income Tax Act, 1922, a claim for bad debt must relate to both the money-lending business and any other business of the assessee. The Court emphasized that the Tribunal's statement of case must include its findings on the facts, not just a summary of arguments. The Court upheld the Tribunal's findings that the loans were not made in the course of the assessee's money-lending business, thus ruling in favor of the department and disallowing the bad debt claim.