Deduction claim on corporate and management charges remitted for fresh High Court consideration after scope was found insufficient.

The deduction dispute concerning corporate and management charges was treated as outside the scope of the connected civil appeal, so the High Court's existing order could not operate as a final determination of that issue. Fresh consideration on merits was therefore required, and the impugned order was set aside with remand to the High Court for de novo examination of the deduction claim.

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Issues: Whether the impugned order of the High Court should be set aside and the matter remitted for de novo consideration on the deduction claim relating to corporate and management charges.

Analysis: The appeal concerned a deduction issue that was stated to be outside the scope of the connected civil appeal arising from the earlier High Court decision. In that circumstance, the existing High Court order could not stand as a final determination of the issue in the present appeal, and fresh consideration by the High Court on merits was required.

Conclusion: The impugned order was set aside and the matter was remitted to the High Court for de novo consideration on merits.

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