1985 (7) TMI 1 - SC - Income Tax

Question of construction of s. 80M - Intercorporate Dividends - it cannot be said that s. 80AA has the effect of imposing any fresh tax with retrospective effect. Section 80AA is clearly declaratory in nature and merely declares what the correct position has always been - held that for deduction of intercorporation dividends u/s 80Mm, the net dividend income forming part of the gross total income is to be considered, and not the full dividend received by the assessee