COMMISSIONER OF INCOME-TAX, NEW DELHI vs ANANT RAO B. KAMAT

The Supreme Court interpreted Section 16(2) of the Indian Income Tax Act, 1922, holding that the rate applicable for grossing up dividends must be based on the year in which the dividend is paid, not the year profits were made. The Court clarified that the term 'rebate' encompasses any rebate granted under statutory orders, not just those under the Indian Finance Act. The judgment of the Rajasthan High Court was upheld, affirming that the relevant Finance Act rates apply to the dividends in question.