https://www.taxtmi.com/caselaws?id=168770 A company engaged in share-dealing and dividend-stripping was held not to be an investment company for the relevant period because the statutory comparison was with its total income as computed for tax purposes, not with a dividend element extracted from trading profit. Dividends received in the course of the share-dealing business formed part of trading receipts, but once that trading profit was ascertained it could not be dissected and re-characterised as investment income for the investment-company test under section 257(2). The surtax direction therefore could not stand. en-us Thu, 18 Jul 1963 00:00:00 +0530 Thu, 26 Mar 2015 11:26:46 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=168770 A company engaged in share-dealing and dividend-stripping was held not to be an investment company for the relevant period because the statutory comparison was with its total income as computed for tax purposes, not with a dividend element extracted from trading profit. Dividends received in the course of the share-dealing business formed part of trading receipts, but once that trading profit was ascertained it could not be dissected and re-characterised as investment income for the investment-company test under section 257(2). The surtax direction therefore could not stand. Case-Laws Income Tax Thu, 18 Jul 1963 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=168770