https://www.taxtmi.com/caselaws?id=5890 The majority upheld the validity of Rule 19A of the Income Tax Rules, 1962, stating that the exclusion of borrowed monies was within the mandate of Section 80J. They reasoned that the term "capital employed" is flexible and can be interpreted to exclude borrowed capital. Additionally, the retrospective amendment made in Section 80J by the Finance (No. 2) Act, 1980, was upheld as clarificatory and necessary for maintaining consistency in tax laws. The dissenting opinion found both the rule and the amendment unconstitutional, emphasizing the arbitrary financial burden imposed on assessees and the disruption of settled financial affairs. en-us Fri, 25 Jan 1985 00:00:00 +0530 Sat, 31 May 2014 15:32:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=5890 The majority upheld the validity of Rule 19A of the Income Tax Rules, 1962, stating that the exclusion of borrowed monies was within the mandate of Section 80J. They reasoned that the term "capital employed" is flexible and can be interpreted to exclude borrowed capital. Additionally, the retrospective amendment made in Section 80J by the Finance (No. 2) Act, 1980, was upheld as clarificatory and necessary for maintaining consistency in tax laws. The dissenting opinion found both the rule and the amendment unconstitutional, emphasizing the arbitrary financial burden imposed on assessees and the disruption of settled financial affairs. Case-Laws Income Tax Fri, 25 Jan 1985 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=5890