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    <title>1964 (6) TMI 56 - HOUSE OF LORDS</title>
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    <description>Dividends received in a dividend-stripping arrangement were held not to form trading receipts for Schedule D Case I computations where the dividends had already borne tax. They were to be left out of the trading profit and loss account because they had been exhausted as a source of income and could not be taxed again indirectly as trading profits. The proposed equitable adjustment to counter any double taxation was rejected for lack of statutory basis. On that footing, the company&#039;s income was treated as mainly investment income, it qualified as an investment company, and the surtax direction was valid.</description>
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    <pubDate>Thu, 04 Jun 1964 00:00:00 +0530</pubDate>
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      <title>1964 (6) TMI 56 - HOUSE OF LORDS</title>
      <link>https://www.taxtmi.com/caselaws?id=169538</link>
      <description>Dividends received in a dividend-stripping arrangement were held not to form trading receipts for Schedule D Case I computations where the dividends had already borne tax. They were to be left out of the trading profit and loss account because they had been exhausted as a source of income and could not be taxed again indirectly as trading profits. The proposed equitable adjustment to counter any double taxation was rejected for lack of statutory basis. On that footing, the company&#039;s income was treated as mainly investment income, it qualified as an investment company, and the surtax direction was valid.</description>
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      <pubDate>Thu, 04 Jun 1964 00:00:00 +0530</pubDate>
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