https://www.taxtmi.com/caselaws?id=36937 In construing the second proviso to rule 3(a), the Bombay HC stated that the amount to be added back is measured by the deduction actually allowed from the surplus of the inter-valuation period, not by the annual average surplus. The scheme required surplus to be computed for the whole inter-valuation period first, with the annual average derived only afterwards, so the later restoration operates by reference to the original deduction. The court also emphasised that taxing language must be given its plain meaning, and equitable considerations cannot alter the statutory computation. en-us Sat, 05 Nov 1977 00:00:00 +0530 Thu, 25 Mar 2010 15:22:09 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=36937 In construing the second proviso to rule 3(a), the Bombay HC stated that the amount to be added back is measured by the deduction actually allowed from the surplus of the inter-valuation period, not by the annual average surplus. The scheme required surplus to be computed for the whole inter-valuation period first, with the annual average derived only afterwards, so the later restoration operates by reference to the original deduction. The court also emphasised that taxing language must be given its plain meaning, and equitable considerations cannot alter the statutory computation. Case-Laws Income Tax Sat, 05 Nov 1977 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=36937