Specific income classification controls super profits tax exclusion for government securities interest received by a non-resident company.

Interest on Government securities received by a non-resident company is excluded from chargeable profits under clause (vi) of rule 1 of the First Schedule to the Super Profits Tax Act, because that clause specifically governs income under the head "Interest on securities." Clause (x) applies only to broader interest received by a non-resident from Government, local authority, or an Indian concern where the item is not already covered by clause (vi). The company's non-resident status does not change the character of the securities income, so the specific classification prevails and the broader clause has no application.

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Issues: Whether interest received from Government securities by a non-resident company was to be excluded in computing chargeable profits under clause (vi) of rule 1 of the First Schedule to the Super Profits Tax Act, 1963, or under clause (x) of that rule.

Analysis: The chargeable profits under the Super Profits Tax Act are computed from total income under the Income-tax Act with only those amounts specifically required by the First Schedule being excluded. Interest on Government securities falls under the distinct head of income "Interest on securities" under the Income-tax Act, and that head is specifically dealt with by clause (vi) of rule 1 of the First Schedule. Clause (x) applies only to the broader category of interest received by a non-resident company from Government, local authority, or Indian concern where the item is not already governed by clause (vi). The status of the assessee as a non-resident company does not alter the character of income derived from Government securities.

Conclusion: Clause (vi) applied and clause (x) had no application. The exclusion had to be made under clause (vi), and the Revenue's contention was accepted.

Ratio Decidendi: Where a statute separately classifies income under a specific head, that specific classification governs the computation and a broader residuary or special-status clause cannot displace it unless the text clearly so provides.

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