JUDGMENT

CHANDRACHUD, CJI. :— The appellant which is a public limited company incorporated under the Indian Companies Act is authorised by its memorandum and articles of association to carry on business, inter alia, as importers, exporters and insurances agents.

2. We are concerned in these appeals with the assessment years 1954-55, 1955-56 and 1956-57 corresponding to the accounting years 1953, 1954 and 1955. the appellant used to carry on business in (i) general insurance, (ii) brokerage and commission, and (iii) import and sale of woollen fabrics, leather beltings, hardware, toilet goods, chemicals, cotton fabrics, etc. The business of import and sale was closed by the appellant towards the end of the calendar year 1952 corresponding to the assessment year 1953-54. In that year the appellant suffered an accumulated business loss of Rs. 56,488/-.

3. From the assessment year 1954-55, that is to say, from the commencement of the calendar year 1953, the appellant started exporting cotton textiles instead of importing woollen fabrics which, as stated earlier, it had ceased to do towards the end of the calendar year 1952. The appellant claimed that the loss of Rs. 56,488/- incurred by i