https://www.taxtmi.com/caselaws?id=64592 Surtax payable by a company was deductible in computing distributable income for the purpose of section 104 of the Income-tax Act, because section 109 had to be read with section 15 of the Companies (Profits) Surtax Act, 1964, which expressly directed deduction of surtax in that computation. Authorities relied on by the Revenue concerned deduction of surtax under section 37 in computing total income and did not override the specific statutory rule governing distributable income. The specific provision in the surtax law therefore prevailed over the general treatment adopted in assessment, with the result that the addition under section 104 could not be sustained. en-us Fri, 14 Jun 1996 00:00:00 +0530 Tue, 08 Feb 2011 17:33:33 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=64592 Surtax payable by a company was deductible in computing distributable income for the purpose of section 104 of the Income-tax Act, because section 109 had to be read with section 15 of the Companies (Profits) Surtax Act, 1964, which expressly directed deduction of surtax in that computation. Authorities relied on by the Revenue concerned deduction of surtax under section 37 in computing total income and did not override the specific statutory rule governing distributable income. The specific provision in the surtax law therefore prevailed over the general treatment adopted in assessment, with the result that the addition under section 104 could not be sustained. Case-Laws Income Tax Fri, 14 Jun 1996 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=64592