B. R. LTD. vs V. P. GUPTA, C.I.T., BOMBAY

The Supreme Court interpreted Section 24(2) of the Income Tax Act, 1922, holding that an unabsorbed loss can only be set off against profits from the 'same business' and not a similar one. The Court established that the terms 'same' and 'similar' have distinct meanings, and the determination of whether two businesses are the same is a mixed question of law and fact, dependent on the specific circumstances of each case. The appellant's claim to set off losses from an import business against profits from an export business was rejected, affirming the lower authorities' decisions.