https://www.taxtmi.com/caselaws?id=61094 ITAT Chandigarh held that, for clause (viii) of rule 1 of the First Schedule to the Companies (Profits) Surtax Act, 1964, the exclusion applies to the gross dividend received, not merely the portion remaining after Chapter VI-A deductions in the income-tax computation, applying a taxpayer-favourable construction where the provision is reasonably capable of two meanings. It further held that rule 4 of the Second Schedule does not extend to Chapter VI-A deductions such as those under sections 80K and 80M, because those deductions are not amounts of income not includible in total income. The Revenue's appeals failed on both issues. en-us Sat, 30 Sep 1978 00:00:00 +0530 Mon, 23 Jan 2012 17:41:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=61094 ITAT Chandigarh held that, for clause (viii) of rule 1 of the First Schedule to the Companies (Profits) Surtax Act, 1964, the exclusion applies to the gross dividend received, not merely the portion remaining after Chapter VI-A deductions in the income-tax computation, applying a taxpayer-favourable construction where the provision is reasonably capable of two meanings. It further held that rule 4 of the Second Schedule does not extend to Chapter VI-A deductions such as those under sections 80K and 80M, because those deductions are not amounts of income not includible in total income. The Revenue's appeals failed on both issues. Case-Laws Income Tax Sat, 30 Sep 1978 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=61094