Section 59 (2) (b) and 131 Group Relief Appeal Department had two grounds in their appeal. First of all, the Commissioner (Appeal) made a mistake in terminating this sanction and made adjustments to the company's losses. Secondly, the Commissioner (Appeal) made a mistake in eliminating the increase in the amount due to catalyst deportation, and Regarding L, the Commissioner dealt with the matter according to proper and legal principles. No intervention was guaranteed in this case, as the conditions for introducing group relief in the country made it clear that the legislature has tried to offer equipment that would allow the immediate use of damages. As they suffer in their early years. Lives encourage investment in the industrial sector. However, the legislature did not want the same facility for commercial concerns, as it would promote relatively low risk trading and discourage investment in industrial enterprises in the relatively high risk area, in the current case of group relief. The company was a beneficiary because he sold his loss in cash in one way and the loss-buying company paid the loss right, because the loss-buying company would have paid the tax authorities if it had subsidized it. Did not meet its earnings against loss of Company Order of Commissioner. (Appeals) cannot be interfered with. On the other hand, the representative of the Department argued that the taxpayer could not afford to pay twice, either through depreciation, and then by debiting the Stores and Spares account, Basic expenses Business expenses