Section 80A(2), Income Tax Act, 1961, provides that the aggi;egate amount ?-- of deductions under Chapter VIA shall not exceed the gross total mcome of t_he c assessee. Under s. SOJ(l), which is in Chapter VIA, where the gross total m- ' come of an assessee includes any profits and gains derived from an industrial undertaking, there shall be allowed, in computing the total income of the assessee, a deduction of so much of the profits and gai113 a~ does not eXCeed the amount calculated at 6 per cent per annum of the capital employed in the industrial undertaking, calculated in the prescribed manner, and referred to as the 'relevant amount'; and, under s. SOJ (3), where the amount of profits and gains derived from the industrial undertaking falls short of the 'relevant amount' D the amount of shortfall, or, where there are no profits and gains, the whole of the 'relevant amount' shall be carried forward and set off against the profits and gains of the next assessment year and so on up to the 7th ass~ment year from the end of the initial assessment year. Section SOK provides that in computing the total income of an assessee, whose gross total income includes any income by way of dividends, there shall be allowed, a deduction from the dividend-income an amount ectual to such part thereof as is attributable to profits and gains derived by the company from an industrial undertaking on which no tax is payable by the company or in respect of which a company is entitled to E a deduction under s. SOJ. Under 5. 197 (3) if by reason of s. SOK. the whole or any portion of dividend payable to a share-holder will be deductible in com· puling the assessee's total income, application may be made to the Income Tax Officer to determine the amount to be deducted, and, on such determination, no t,ax shall be deducted at source on such amount.
