https://www.taxtmi.com/caselaws?id=6500 For computing reduction in rebate under Paragraph D of Part II of the First Schedule to the Finance Act, 1958, the relevant profits and gains are those of the previous year in which the dividends were distributed. The statutory fiction in the Explanation is confined to the language of the clause, which repeatedly refers to "the previous year" and "for that year"; it cannot be extended to profits of earlier years, even if they were the source of the dividend distribution. The computation therefore had to be made only by reference to the previous year, and the answer was against the assessee and in favour of the Revenue. en-us Tue, 09 Nov 1976 00:00:00 +0530 Fri, 05 Dec 2008 00:00:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=6500 For computing reduction in rebate under Paragraph D of Part II of the First Schedule to the Finance Act, 1958, the relevant profits and gains are those of the previous year in which the dividends were distributed. The statutory fiction in the Explanation is confined to the language of the clause, which repeatedly refers to "the previous year" and "for that year"; it cannot be extended to profits of earlier years, even if they were the source of the dividend distribution. The computation therefore had to be made only by reference to the previous year, and the answer was against the assessee and in favour of the Revenue. Case-Laws Income Tax Tue, 09 Nov 1976 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=6500