813/CBDT.

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..... le to the Companies (Profits) Surtax Act, 1964 and Explanation 1(b) in Para F of Part I of the First Schedule to Finance Act, 1966. The expression "on the first day of the previous year" has not been defined either in the companies (Profits) Surtax Act, 1964 or in the Finance Act 1966. 2. As per principle of construction, when a particular word is not specially defined it should be construed in .....

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..... al in earning the income from which the dividends are distributed. As such, it would be logical as well as consistent with the principles of accountancy that any change in the capital structure effected on the first day of the previous year could not be really taken into account for the purpose of determining the paid up capital . Similar considerations will apply to the relevant provisions of the .....

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