https://www.taxtmi.com/caselaws?id=7566 Explanation 2 to section 23A is applied separately to the industrial and non-industrial segments of a composite business, so the prescribed distribution percentage must be worked out on each segment as though it were the company's total income for that part. The analysis states that dividends and taxes are correspondingly apportioned, but the statute does not require actual dividends to be divided strictly in the ratio of industrial and non-industrial profits. Where the statutory percentage has been fully distributed on the industrial profits, no additional super-tax is leviable on that segment, and the revenue cannot club both segments together to charge super-tax on the undistributed balance. en-us Thu, 23 Jan 1969 00:00:00 +0530 Mon, 02 Mar 2009 13:20:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=7566 Explanation 2 to section 23A is applied separately to the industrial and non-industrial segments of a composite business, so the prescribed distribution percentage must be worked out on each segment as though it were the company's total income for that part. The analysis states that dividends and taxes are correspondingly apportioned, but the statute does not require actual dividends to be divided strictly in the ratio of industrial and non-industrial profits. Where the statutory percentage has been fully distributed on the industrial profits, no additional super-tax is leviable on that segment, and the revenue cannot club both segments together to charge super-tax on the undistributed balance. Case-Laws Income Tax Thu, 23 Jan 1969 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=7566