Law:

Section:

Section 2(6AA) , read with section 8, of the Indian Income-tax Act, 1922 - Earned income - Assessment year 1946-47 - Whether section 8 which deals with interest on securities is separate and distinct head, and if an income is chargeable under that head, it is not open either to assessee or to department to change head and claim to tax it under different head - Held, yes - Assessees claimed earned income relief in respect of interest on securities on ground that aforesaid securities, which they purchased and sold as part of their business, formed stock-in-trade and that profits arising in such purchase and sale including interest on securities should be treated as business profit - Whether interest on securities must be treated as income from securities within meaning of section 8 and chargeable under that head, assessee was not entitled to claim earned income relief in respect of such interest - Held, yes FACTS The assessees had several sources of income, viz., interest on securities, profits of business, dividends and other interests. The business, however, ended in loss. The assessees claimed earned income relief in respect of the interest on securities on the ground that the securities, the Government Promissory Notes, which they purchased and sold as part of their business, formed stock-in-trade and that the profits arising in such purchase and sale including the interest on securities should be treated as business profits. The revenue authorities rejected the said claim on the ground that the interest on securities was assessable under section 8 of the 1922 Act and could not be treated as part of the business income. On reference: HELD The income-tax is one single tax on the aggregate total income of assessee. It is, however, classified under various heads and made chargeable under such heads. Section 6 classifies the heads. The classification under various heads however does not mean that there are as many taxes as there are heads of income. The tax is one tax on the aggregate of the income. If once the income is dealt with under the proper head, it cannot be dealt with again under another head as when once the income is taxed, its source for purposes of…

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