https://www.taxtmi.com/caselaws?id=181705 A fiscal provision on income from securities was construed strictly, with ambiguity resolved in favour of the assessee. Interest paid on borrowed capital used to invest in securities was held deductible in full under the first proviso where the borrowing could not be specifically traced to particular investments, and the department's attempt to apportion that interest between taxable and tax-free securities was rejected. The second proviso was treated as independently excluding the whole of the interest on income-tax-free securities from computation. The result was that artificial proportionate allocation was not permitted unless the Act clearly required it. en-us Fri, 07 Dec 1945 00:00:00 +0530 Fri, 22 Apr 2016 12:13:02 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=181705 A fiscal provision on income from securities was construed strictly, with ambiguity resolved in favour of the assessee. Interest paid on borrowed capital used to invest in securities was held deductible in full under the first proviso where the borrowing could not be specifically traced to particular investments, and the department's attempt to apportion that interest between taxable and tax-free securities was rejected. The second proviso was treated as independently excluding the whole of the interest on income-tax-free securities from computation. The result was that artificial proportionate allocation was not permitted unless the Act clearly required it. Case-Laws Income Tax Fri, 07 Dec 1945 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=181705