Similarly apportioned, the words 'similarly apportioned' which occur in the explanation mean apportioned 'with reference to the amounts of profits and gains attributable to the two parts of the company's business'. Thus, the explanation first refers to an apportionment or splitting up and then provides that the dividends and taxes shall be similarly apportioned, that is to say, similarly split up. Accordingly, the words 'similarly apportioned' convey a definite meaning and are not ambiguous. 'Similarly apportioned' means simply 'similarly split up', CIT v. T.V. Sundaram Iyenger and Sons (P) Ltd., AIR 1976 SC 255 (260): (1976) 1 SCC 77: (1975) Supp SCR 93. (Income Tax Act, 1922 s. 23A, Expl. 2)
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