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    <title>1936 (5) TMI 37 - PRIVY COUNCIL</title>
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    <description>Section 14(2)(a) of the Income Tax Act, 1922 was construed according to its ordinary and natural meaning: where a company&#039;s profits or gains had been assessed to income-tax, the shareholder&#039;s dividend was exempt without apportioning it between taxed and untaxed components. The language did not require tracing the dividend to particular sources or limiting relief to the proportion attributable to taxed profits, because that approach would create uncertainty and add factual inquiries not found in the text. On that construction, the exemption applied whenever the company&#039;s profits had been assessed, and the answer favoured the revenue.</description>
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    <pubDate>Tue, 26 May 1936 00:00:00 +0530</pubDate>
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      <title>1936 (5) TMI 37 - PRIVY COUNCIL</title>
      <link>https://www.taxtmi.com/caselaws?id=292815</link>
      <description>Section 14(2)(a) of the Income Tax Act, 1922 was construed according to its ordinary and natural meaning: where a company&#039;s profits or gains had been assessed to income-tax, the shareholder&#039;s dividend was exempt without apportioning it between taxed and untaxed components. The language did not require tracing the dividend to particular sources or limiting relief to the proportion attributable to taxed profits, because that approach would create uncertainty and add factual inquiries not found in the text. On that construction, the exemption applied whenever the company&#039;s profits had been assessed, and the answer favoured the revenue.</description>
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      <pubDate>Tue, 26 May 1936 00:00:00 +0530</pubDate>
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