permissible deductions, provides as one of such deductions in r. 1 ( 1) (xi) "any expenditure (not being in the nature of capital expenditure or personal expense of the person to whose business this Ordinance applies) laid out or expended wholly and exclusively for the purposes of such business~'. If this provision were applied for computing the profits of a company as an unit of assessment, there could be no dispute that genera.Uy speaking the remuneration paid to a managing-agent would be an admissible deduction. It hardly needs to be mentioned that the remuneration received by a managing-agent would be profits from business on which he would be liable to tax under the Ordinance, being a profit from business as defined in s. 2(5) subject only to the condition that the amount of the profit brought it within the taxable limit. To this prima facie rule as regards the manner in whic~ the profits derived by a company are to be computed r. 4 enacts an exception, in the case of those companies in which the Directors have a controlling interest. But the application of this special rule as regards companies under the management of Directors with controlling interest is, however, subject, among others, to proviso (b) not applying to the case. In other words, if proviso (b) saved the case, the special. rule as' to controlled companies would cease to be applicable and the remuneration paid would be deductible in the computation of the companies' profits. This turns on whether the remuneration paid to the managing·agent "is included in the profit& of the managing agent's business". The words used being "is included" there is no doubt that an actual incluiion is posited. But this, however, does not sol rn the problem, for the "inclusion in the profi'.;s'' might refer to three distinct "inclusions" : (1) the inclusion by the managing agents as an assessee for the· purposes of his individual assessment, i.e., in his return, (2) the inclusion by the a1111e.11ing authority in the order of
