Sen, J. - (1.) These are appeals from a judgment of the Andhra Pradesh High Court which answered the following question of law in the affirmative and against the assessee.:-"Whether on the facts and in the circumstances of the case, the sums of Rs. 4,12,780/-and Rs. 5,50,000/- are liable to be excluded under R. 1(xi)(a) of the Surtax Rules in computing the chargeable profits in Surtax assessments for the assessment years 1971-72 and 1972-73 -
(2.) The assessment years involved in this case are 1971-72 and 1972-73 for which the relevant previous years were calendar years 1970 and 1971 respectively.
(3.) The dispute in this case is about computation of chargeable profits of banking company. Chargeable Profits has been defined in sub-sec. (5) of S. 2 of the Companies (Profits) Surtax Act, 1964 (for short the Act) to mean the total income of an assessee computed under the Income-tax Act, 1961 for any previous year or years,................and adjusted in accordance with the provisions of the First Schedule.";