1988 (12) TMI 66

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....r the opinion of this court are : "(1) Whether, on the facts and in the circumstances of the case, the Income-tax Appellate Tribunal erred in law in holding that under rule 1 (viii) of the First Schedule to the Companies (Profits) Surtax Act, 1964, the gross dividend and not the net dividend which actually formed part of the total income of the assessee was to be excluded from the total income of....