JUDGMENT 1. These two appeals filed by the Revenue involve a common question of law, and are, therefore, being decided by this common order. Both the appeals have been admitted by different orders dated July 30, 2007, and April 19, 2006, but by framing the same substantial question of law. It is a different story, that the question as framed in Appeal No. 45/2006, as such, does not arise in Appeal No. 111/2007, inasmuch as Appeal No. 45/2006 arises out of the appeal of the assessee filed before the Tribunal, against invoking of the powers under section 263 of the Income-tax Act, 1961, while Appeal No.111/2007 arises out of the regular appeal, filed by the assessee, with respect to the different year. But then the central question, about the entitlement of the assessee, to claim exemption under section 10B, on the interest income, earned from M/s. Wolkem India Ltd. is involved in both the appeals, and, therefore, these two appeals are involving common question of law. 2. Bereft of unnecessary details, the necessary facts of Appeal No. 45/2006 are, that the assessee and Wolkem India Ltd. admittedly are sister concerns. The assessee purchased goods from Wolkem India Ltd., and for such purchase, amount is paid in advance to the seller, and that advance amount yields interest income to the assessee. It is with respect to this income of interest, that the assessee claimed exemption under section 10B, which was allowed by the Assessing Officer, holding that this income is attributable to the business of the undertaking, and was thus exempt under section 10B. Against that order, powers under section 263, being revisional powers were invoked, and, vide order dated February 12, 1996, the order of the Assessing Officer was set aside, and the matter was restored back to the Assessing Officer, for holding enquiries, and passing a fresh order. The revisional authority found that there is nothing on record to show that Wolkem India Ltd. had desired to deposit of any specific amount of advance prior to its agreeing to supply raw material to its own sister concern, nor is there anything to indicate that the Assessing Officer examined the case from this angle, before allowing exemption under section 10B. Likewise, it was also considered, that even if there is a business practise, where the suppliers of certain goods do require advance for future purchase, the transactions of the assessee with its own sister concern is to be considered on a different footing. Thus, it was found, that the Assessing Officer could not be said to be right in taking the view, that interest received by the assessee, from Wolkem India Ltd. was materially different in nature, from the interest in respect of other parties, without due enquiries. Reliance was placed on the judgment of this court in Murli Investment Co. v. CIT (1987) 167 ITR 368 , wherein the income derived from surplus fund was not considered to be business income. With these findings, it was concluded, that while considering the total taxability in respect of the different items, erroneous view was taken, without due enquiry regarding income of Wolkem India Ltd., and it is prejudicial to the interests of the Revenue. 3. This order was challenged by the assessee before the learned Tribunal, on the ground, that the provisions of section 263 could not be invoked. The learned Tribunal found that the Assessing Officer has applied his mind to the facts of the case, and treated the income received from Wolkem India Ltd. as business income. Therefore, the Tribunal did not agree with the view of the Commissioner of Income-tax that the Assessing Officer had not made due enquiries and had not applied his mind to the facts of the case. Reference was also again made to the judgment of this court in Murli Investment's case (1987) 167 ITR 368 (Raj), and it was held that since the assessee is having regular business dealings of purchase from M/s. Wolkem India Ltd. which takes advance from the assessee against the sales made by it to the assessee and, therefore, only this interest could be considered as income from the business undertaking, as the same has arisen during the course of regular business. Thus, it was held that interest income amount received from Wolkem India Ltd. was rightly held to be income from business, by the Assessing Officer, and the order of the Commissioner of Income-tax was quashed. This matter related to the assessment year 1993-94. 4. Thus, it was held that interest income amount received from Wolkem India Ltd. was rightly held to be income from business, by the Assessing Officer, and the order of the Commissioner of Income-tax was quashed. This matter related to the assessment year 1993-94. 4. Then regarding the assessment year 1994-95, the learned Commissioner relying upon the order of the Tribunal dated July 14, 2003, allowed the exemption, which was affirmed by the learned Tribunal, and is under challenge in Appeal No. 111/2007. 5. It is contended by learned counsel for the Revenue, that undisputedly, the amount of interest was received by the assessee from Wolkem India Ltd. and the income of the interest is always chargeable as "income from other sources" under section 56 of the Act, and since section 10B does not provide for exemption about income from other sources, the learned Tribunal was in error in granting exemption. Reliance on the decision in Murli Investment's case (1987) 167 ITR 368 (Raj) was reiterated to contend that in the present case also the interest was the yield of the amount deposited by the assessee with the seller and was independently received by the assessee as interest and, therefore, it cannot be treated as business income, so as to entitle the assessee to exemption under section 10B. 6. The assessee on the other hand supported the impugned order, by contending that the income was the result of business transactions between the assessee and seller and, therefore, it clearly falls within the definition of "profits and gains" and, therefore, the assessee was entitled to exemption under section 10B and the same has rightly been allowed by the learned Tribunal. 7. We have considered the submissions. 8. In our view, a look at the language of section 10B shows that exemption was admissible with respect to any profits and gains derived by the assessee under the circumstances specified in the section. Since we are called upon to decide the question only as to whether the amount received by the assessee falls within the expression "profits and gains" we need not dilate on any other aspect of the matter. 9. The expression "profits and gains" as such has not been defined in the Income-tax Act (as the relevant provision existed at the relevant time). 9. The expression "profits and gains" as such has not been defined in the Income-tax Act (as the relevant provision existed at the relevant time). However, section 2(24) does define the "income" as including some nineteen items, and item No. (i) is "profits and gains". Then other items include in sub-clause (v) being any sum chargeable to Income-tax under section 59, and, according to section 59, the provisions of section 41(1) shall apply so far as may be in computing the income of an assessee under section 56. Section 56, as referred to above, provides for income from other sources. Section 56(1)(id) covers income by way of interest on securities but also excludes therefrom such income as well if the income is chargeable to Income-tax under the head "Profits and gains of business or profession". Then, according to section 14, the computation of total income is to be made for the purpose of charge of Income-tax. Section 14 as such does not separately classify income from interest, such income is sought to be covered only under section 14F which covers "Income from other sources", which is defined as above under section 56. Thus, from the above provisions, it is clear that income from other sources, if falling within the definition of income, is taxable by virtue of section 14, and thus it is taxable income, but then, it is only one of the species of income, as defined in section 2(24). Clause D of section 14 is about the head "Profits and gains of business or profession" . 10. Thus, it is clear that for all purposes, profits and gains of business or profession and income from other sources are treated by the Act to be different species of income. In this background, section 2(24) as such, does not categorise separately profits and gains of business or profession. Thus, the expression "profits and gains" as used in section 2(24), is a wider expression, and is not confined to "profits and gains of business or profession" . 11. In this background, the language of section 10B, again, provides for exemption, with respect to any "profits and gains" derived by the assessee, and is not confined to "profits and gains of business or profession" as provided under section 14D. 12. Then for the definition of "profits and gains", we are left to seek assistance from other sources. 11. In this background, the language of section 10B, again, provides for exemption, with respect to any "profits and gains" derived by the assessee, and is not confined to "profits and gains of business or profession" as provided under section 14D. 12. Then for the definition of "profits and gains", we are left to seek assistance from other sources. Dictionary meaning, as such, does not provide much of assistance. Then Arthur Average Association for British, Foreign and Colonial Ships, In re : Ex parte Hargrove and Co. (1875) LR 10 Ch App 545 , the meaning of the word "gain" has been given as acquisition, and has no other meaning. Gain is something obtained or acquired, and is not limited to pecuniary gain. Regarding "profit", in general, the profit means the price received over the cost of purchasing and handling the goods, it means pecuniary gain, as held in Straton v. Cartmell 42 A.2d 419 ; 114 Vt 191. In Oliver v. Halstead 86 S. E.2d 858 ; 196 vz. 992 , the word "profit", as ordinarily used, is held to mean, the gain made upon any business or investment and does not include compensation for labour. Then in George E. Warren Co. v. U. S., D. C. Mass, 76 E. Supp. 587, 591, it has been held that "profits" is capable of numerous constructions and for any given use its meaning must be derived from the context. Likewise, in Gulf Refining Co. v. Stanford 30 So 2d 516 ; 202 Miss 602 ; 173 ALR 1099, it has been held that "profit" is an elastic and ambiguous word, often properly used in more than one sense; its meaning in a written instrument is governed by the intention of the parties appearing therein but any accurate definition thereof must always include the element of gain. Similar definition has been given in various other judgments. 13. If considered from these stand points, there is no escape for the conclusion that the income derived by the assessee from Wolkem India Ltd. does fall within the expression "profits and gains" . 14. That being the position, on the aspect, as considered by the authorities concerned below, we do not find the order of the Tribunal to be suffering from any error, so as to interfere in our appellate jurisdiction. 14. That being the position, on the aspect, as considered by the authorities concerned below, we do not find the order of the Tribunal to be suffering from any error, so as to interfere in our appellate jurisdiction. The question as framed is required to be, answered against the Revenue and in favour of the assessee and is accordingly answered. 15. The appeals thus have no force and are dismissed. *******