Such income by way of dividends, the words 'such income by way of dividends' in s. 80M of Income Tax Act, is referable not only to the category of income included in the gross total income but also to the quantum of the income so included. On a plain grammatical construction, it is obvious that the words 'such income by way of dividends' must have reference to the income by way of dividends mentioned earlier and that would be income by way of dividends from a domestic company which is included in the gross total income, Disributors (Baroda) Pvt. Ltd. v. Union of India, AIR 1985 SC 1585: (1986) 1 SCC 43: (1985) Supp 1 SCR 778.
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