https://www.taxtmi.com/caselaws?id=35795 Tax credit certificates issued under section 280ZB were held not to be income for the purposes of rule 4 of the Second Schedule to the Companies (Profits) Surtax Act, 1964. Applying the ordinary and commercial meaning of income, the receipt was treated as a refund-like incentive subject to statutory conditions, not as a trading or earning return freely disposable as income ordinarily is. Its inclusion among exempt items under section 10(28) did not change its character. Because the receipt was not income in substance, it could not be taken into account to reduce capital for surtax purposes, and the assessee succeeded on reference. en-us Tue, 24 Mar 1981 00:00:00 +0530 Tue, 16 Mar 2010 16:51:31 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=35795 Tax credit certificates issued under section 280ZB were held not to be income for the purposes of rule 4 of the Second Schedule to the Companies (Profits) Surtax Act, 1964. Applying the ordinary and commercial meaning of income, the receipt was treated as a refund-like incentive subject to statutory conditions, not as a trading or earning return freely disposable as income ordinarily is. Its inclusion among exempt items under section 10(28) did not change its character. Because the receipt was not income in substance, it could not be taken into account to reduce capital for surtax purposes, and the assessee succeeded on reference. Case-Laws Income Tax Tue, 24 Mar 1981 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=35795