https://www.taxtmi.com/caselaws?id=273199 For double tax relief under paragraph 9 of Schedule 16 to the Income Tax Act 1952, the expression "the relevant profits" is construed as the company's distributable profits shown in its accounts, not the profits computed for foreign tax assessment. The provision links relief to the profits of the period out of which the dividend is paid and to profits available for distribution, while the proviso confirms that earlier periods are considered only to the extent needed to cover any excess dividend. The alternative approach based on foreign tax profit computations, and the argument that a payment may be treated as coming out of the more favourable fund, were rejected. en-us Wed, 16 Jul 1969 00:00:00 +0530 Mon, 11 Jun 2018 15:43:30 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=273199 For double tax relief under paragraph 9 of Schedule 16 to the Income Tax Act 1952, the expression "the relevant profits" is construed as the company's distributable profits shown in its accounts, not the profits computed for foreign tax assessment. The provision links relief to the profits of the period out of which the dividend is paid and to profits available for distribution, while the proviso confirms that earlier periods are considered only to the extent needed to cover any excess dividend. The alternative approach based on foreign tax profit computations, and the argument that a payment may be treated as coming out of the more favourable fund, were rejected. Case-Laws Income Tax Wed, 16 Jul 1969 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=273199