https://www.taxtmi.com/caselaws?id=58097 Timely rectification applications under section 13 of the Companies (Profits) Surtax Act created an enforceable right to a merits decision, and delay by the authority did not defeat jurisdiction. The doctrine of merger applied only to matters actually adjudicated in appeal, so rectification was maintainable on the unresolved exclusion of interest income. On the profit computation issue, interest received from Indian banks and other Indian parties could be excluded from chargeable profits under rule 1(x) of the First Schedule, but interest from the First National City Bank was not eligible for exclusion as interest from an Indian concern. The assessee obtained only partial relief. en-us Thu, 28 Apr 1988 00:00:00 +0530 Fri, 17 Dec 2010 13:12:42 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=58097 Timely rectification applications under section 13 of the Companies (Profits) Surtax Act created an enforceable right to a merits decision, and delay by the authority did not defeat jurisdiction. The doctrine of merger applied only to matters actually adjudicated in appeal, so rectification was maintainable on the unresolved exclusion of interest income. On the profit computation issue, interest received from Indian banks and other Indian parties could be excluded from chargeable profits under rule 1(x) of the First Schedule, but interest from the First National City Bank was not eligible for exclusion as interest from an Indian concern. The assessee obtained only partial relief. Case-Laws Income Tax Thu, 28 Apr 1988 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=58097