Judgement

RAMASWAMI, J.: These appeals are brought by certificate from the judgment of the Bombay High Court dated March 2, 1966 in Income-tax Reference No. 73 of 1962.

2. The appellant company, hereinafter called the assessee company was incorporated on July 29, 1924, as an investment company, the objects of which are set out in clause III of the memorandum of association and more particularly in sub-cls. (1), (2), (15) and (16) of that clause. The assessment years in question are 1943-44 to 1948-49, excepting the year 1947-48, According to its petition made in the High Court, the assessee company dealt with its assets as follows:

"The petitioner company purchased during the period lst July, 1925, to 30th June, 1928, shares of the value of Rs. 1,86,47,789 major portion of which was comprised of shares in the Sassoon Group of Mills. During the year ended 30th June, 1929, the petitioner company promoted two companies known as Loyal Mills Ltd., and Hamilton Studios Ltd., and took over all their shares of the value of Rs. 10 1/2 lacs. In the year 1930, the petitioner company purchased shares of Rs. 1,33,930. During the period of 9 years from 1st July, 1930, to 30th July, 1939, no purchas