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    <title>1992 (2) TMI 20 - GUJARAT High Court</title>
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    <description>Special surcharge under the Finance (No. 2) Act, 1967 was confined to the unearned income actually included in assessed total income after admissible deductions and losses, and could not be levied on a gross figure exceeding that total income. The computation adopted by the Revenue depended on interpretation of the phrase relating to unearned income included in total income, so it was not a patent mistake apparent from the record. That interpretative dispute therefore fell outside rectification under section 154 of the Income-tax Act, 1961, with the result that both points were decided in favour of the assessee.</description>
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    <pubDate>Thu, 13 Feb 1992 00:00:00 +0530</pubDate>
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      <link>https://www.taxtmi.com/caselaws?id=21116</link>
      <description>Special surcharge under the Finance (No. 2) Act, 1967 was confined to the unearned income actually included in assessed total income after admissible deductions and losses, and could not be levied on a gross figure exceeding that total income. The computation adopted by the Revenue depended on interpretation of the phrase relating to unearned income included in total income, so it was not a patent mistake apparent from the record. That interpretative dispute therefore fell outside rectification under section 154 of the Income-tax Act, 1961, with the result that both points were decided in favour of the assessee.</description>
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      <pubDate>Thu, 13 Feb 1992 00:00:00 +0530</pubDate>
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