https://www.taxtmi.com/caselaws?id=36815 Section 49BB was treated as an integrated scheme combining the relief provision, the deeming fiction in Explanation I, and the computation rule in Explanation II. The deeming fiction applied to every claim for relief under the section and was not limited to dividends partly paid out of taxed and current profits. Distributable income for relief had to be computed only by reference to the relevant previous year's allowance and profit-and-loss provision, not by aggregating figures from earlier years since the company's inception. Relief was therefore confined to the balance dividend not absorbed by the deemed distributable income. en-us Wed, 28 Jun 1978 00:00:00 +0530 Wed, 24 Mar 2010 16:51:56 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=36815 Section 49BB was treated as an integrated scheme combining the relief provision, the deeming fiction in Explanation I, and the computation rule in Explanation II. The deeming fiction applied to every claim for relief under the section and was not limited to dividends partly paid out of taxed and current profits. Distributable income for relief had to be computed only by reference to the relevant previous year's allowance and profit-and-loss provision, not by aggregating figures from earlier years since the company's inception. Relief was therefore confined to the balance dividend not absorbed by the deemed distributable income. Case-Laws Income Tax Wed, 28 Jun 1978 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=36815