https://www.taxtmi.com/caselaws?id=38966 Rule 19A of the Income-tax Rules could not restrict the computation of "capital employed" under section 80J to the value of assets on the first day of the computation period, because the statutory relief was intended to promote investment in newly established industrial undertakings and the Act did not require such a narrow date-specific method. The earlier legislative scheme and computation rules showed that capital employed was not confined to opening-day value unless the legislature said so expressly. Rule 19A was therefore ultra vires section 80J to that extent, and the assessee was entitled to a broader computation basis; the disallowance by the Income-tax Officer could not stand. en-us Fri, 12 Sep 1975 00:00:00 +0530 Sat, 10 Apr 2010 16:05:23 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=38966 Rule 19A of the Income-tax Rules could not restrict the computation of "capital employed" under section 80J to the value of assets on the first day of the computation period, because the statutory relief was intended to promote investment in newly established industrial undertakings and the Act did not require such a narrow date-specific method. The earlier legislative scheme and computation rules showed that capital employed was not confined to opening-day value unless the legislature said so expressly. Rule 19A was therefore ultra vires section 80J to that extent, and the assessee was entitled to a broader computation basis; the disallowance by the Income-tax Officer could not stand. Case-Laws Income Tax Fri, 12 Sep 1975 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=38966