https://www.taxtmi.com/caselaws?id=36966 Under the Super Profits Tax Act, the cost of shares held as investments had to be excluded from the capital base because the test in the Second Schedule turns on the character of the asset and whether its income is not includible in chargeable profits, not on actual receipt or actual exclusion of dividend in the relevant year. The scheme of the Act treats that exclusion as independent of fortuitous dividend inclusion in the total income computation. The Calcutta HC therefore upheld reduction of capital by the cost of the shares and answered the question in favour of the Revenue. en-us Thu, 06 Jan 1977 00:00:00 +0530 Thu, 25 Mar 2010 16:19:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=36966 Under the Super Profits Tax Act, the cost of shares held as investments had to be excluded from the capital base because the test in the Second Schedule turns on the character of the asset and whether its income is not includible in chargeable profits, not on actual receipt or actual exclusion of dividend in the relevant year. The scheme of the Act treats that exclusion as independent of fortuitous dividend inclusion in the total income computation. The Calcutta HC therefore upheld reduction of capital by the cost of the shares and answered the question in favour of the Revenue. Case-Laws Income Tax Thu, 06 Jan 1977 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=36966