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The High Court of Madras, in compliance with a court direction, ruled that no portion of the capital should be deducted under rule 4 of the Second Schedule in respect of the deduction granted under section 80M of the Income-tax Act, 1961, in computing the capital employed. This decision was based on a Supreme Court ruling in Second ITO v. Stumpp, Schuele and Somappa P. Ltd. [1991] 187 ITR 108. The court answered the question in the affirmative and against the Department, with no costs.
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