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    <title>1980 (10) TMI 26 - GUJARAT High Court</title>
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    <description>Deductions under Chapter VI-A of the Income-tax Act, 1961 are treated as deductions from total income and not as income, profits or gains that are &quot;not includible&quot; in total income for rule 4 of the Second Schedule to the Companies (Profits) Surtax Act, 1964. The decisive expression &quot;not includible&quot; covers only income that is inherently incapable of inclusion under sections 4 and 5 of the Income-tax Act or is excluded under section 10; it does not extend to amounts first included in total income and then withdrawn by deduction under Chapter VI-A. The analysis states that this distinction governs the application of rule 4.</description>
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    <pubDate>Thu, 30 Oct 1980 00:00:00 +0530</pubDate>
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      <title>1980 (10) TMI 26 - GUJARAT High Court</title>
      <link>https://www.taxtmi.com/caselaws?id=35833</link>
      <description>Deductions under Chapter VI-A of the Income-tax Act, 1961 are treated as deductions from total income and not as income, profits or gains that are &quot;not includible&quot; in total income for rule 4 of the Second Schedule to the Companies (Profits) Surtax Act, 1964. The decisive expression &quot;not includible&quot; covers only income that is inherently incapable of inclusion under sections 4 and 5 of the Income-tax Act or is excluded under section 10; it does not extend to amounts first included in total income and then withdrawn by deduction under Chapter VI-A. The analysis states that this distinction governs the application of rule 4.</description>
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      <pubDate>Thu, 30 Oct 1980 00:00:00 +0530</pubDate>
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