https://www.taxtmi.com/caselaws?id=37706 Rule 2 of the Second Schedule to the Companies (Profits) Surtax Act, 1964 applies only when the relevant exclusion under rule 1 of the First Schedule actually operates in the assessment year. The Madras High Court held that the cost of assets cannot be reduced from statutory deduction merely because those assets were capable of yielding exempt income; the assessee must in fact have derived income of the kind covered by clauses (iii), (vi) or (viii) of rule 1. A contrary reading would produce an anomalous result inconsistent with the statutory scheme and the legislative object, and the court also relied on Form No. 1 in the Surtax Rules. The reference was answered in favour of the assessee. en-us Wed, 16 Nov 1977 00:00:00 +0530 Wed, 31 Mar 2010 15:40:43 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=37706 Rule 2 of the Second Schedule to the Companies (Profits) Surtax Act, 1964 applies only when the relevant exclusion under rule 1 of the First Schedule actually operates in the assessment year. The Madras High Court held that the cost of assets cannot be reduced from statutory deduction merely because those assets were capable of yielding exempt income; the assessee must in fact have derived income of the kind covered by clauses (iii), (vi) or (viii) of rule 1. A contrary reading would produce an anomalous result inconsistent with the statutory scheme and the legislative object, and the court also relied on Form No. 1 in the Surtax Rules. The reference was answered in favour of the assessee. Case-Laws Income Tax Wed, 16 Nov 1977 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=37706