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A
GUID E
ΤΟ
CEYLON INCOME TAX
BY
S. SUBRAMANIAM
A BOOK EVERY TAXPAYER SHOULD READ
Price Rs. 250
Printed and published by THE TIMES OF CEYLON COMPANY, LIMITED, PRINTERS AND PUBLISHERS, CoLOMBO, CEYLON
I941

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PREFACE
In this book the author has endeavoured to set out the substance of the Income Tax Law of Ceylon in an easily intelligible form and, wherever necessary, has given examples to make the more intricate sections of the Ordinance as clear as possible. It is not intended that this treatise should be a complete survey of all the provisions of the Income Tax Ordinance. It is meant chiefly to serve the needs of the individual tax-payer both resident and non-resident. The large majority of tax-payers attend to their income tax affairs themselves, and it is hoped that this book will be found to be of help to them, as most of the difficulties they are likely to encounter are explained in its pages. Whether one likes it or not, income tax has come to stay, and it behoves those who pay the tax as well as those who are near the border line to make themselves acquainted with the provisions of the Ordinance.
In view of the writer's official position he desires to make it clear that this book contains his personal views and not those of the Income Tax
Department.
S. S. Colombo, March, 1941.

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CONTENTS
CHAPTER PAGE
I. GENERAL Q − O Basis of liability ... Disclosure of liability Liability of residents Estimated assessments ... Authorised representative Exemptions - Classification of income ... Basis other than normal preceding year
II. AGRICULTURE
9 Mature area, immature area, new clearing 9 Expenses ... - 9 Proceeds of sale of coupons 9 Travelling... 9
III. EMPLOYMENT ... á n s a so . . . I2 What are “Profits from employment' a ... 2 Leave pay... - us - ... I2 Rental value of free hous a w a ... Is Commission and bonus ... . . . k a . . . . .3 Withdrawals from provident fund ... . . . 4. Travelling allowance ... a de • I4
Retirement from service... o a . . . I4
IV. TRADE, BUSINESS, PROFESSION, Etc. O . . . IS

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νί
CHAPTER
PAGE
V. INTEREST 16 Basis . I6 Interest in arrear... Ι6 Irrecoverable interest I6 Deductions from interest 17 Interest received by money-lenders 17
VI. DIVIDENDS ... e os e - - - 18 Dividends paid by companies resident in Ceylon 18. Dividends paid by sterling companies which pay
Ceylon tax wo w - 0 . . . 9
VII. RENT OF LAND AND BUILDINGS 2
Annual value, net annual value, and rental value 2.
VIII. DEDUCTIONS 24 Allowable deductions 24 Expenses not allowable ... 25
IX. STATUTORY INCOME, ASSESSABLE INCOME,
AND TAXABLE INCOME ... ... 26 Statutory income... 26 Assessable income 26 Taxable income ... 28 Proportionate allowance... 3o
X. PARTNERSHIP 3. Firm not assessable 3.
XI. RESIDENCE ... up g T. . . . 33
" Resident' although absent from Ceylon for twelve
months ... a sis a . . . 33 To be a "resident' six months’ stay in Ceylon
required a a w . . . 33

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CHAPTER PAGE
XII. SEPARATE ASSESSMENTS 35 Income of wife is income of husband ... 多究 Resident spouse agent of non-resident spouse... 3S Both spouses resident ... ჯ6 One spouse resident and the other non-resident 4. XIII. RATES OF TAX 43
XIV. DEDUCTION AT SOURCE 48 Deduction by resident companies - - - ... 48 Deduction from rent, annuity, etc., payable to person
out of Ceylon ... » R a м () и Q w 4 48
XV. EXECUTORS... so
XVI. NON-RESIDENTS ... 52 Services rendered outside Ceylon а о «и 52 Income for past services rendered in Ceylon ... 52 Non-resident individuals w - w 8 . 52 Business transacted on behalf of non-resident 52
XVII. TEMPORARY RESIDENTS 53
XVIII. PROVIDENT AND PENSION FUNDS ... 54 Provident funds ... 54 Pension funds 54
XIX. DOUBLE TAX RELIEF . . . SS
Double tax relief-United Kingdom tax- section
45 (1) ... 0. . . . SS Double tax relief-Empire tax-section 46 55 British India and Burma ჯ6 Australia and New Zealand ... 57 Relief under section 45 (2) 57
XX, PAYMENT OF TAX 62.

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CHAPTER PAGE
XX. APPEALS a 63 Appeal to the Commissioner 63 Appeal to the Board of Review 64 Appeal to the Supreme Court ... 64 Appeal to the Privy Council 64
APPENDICES
Form of income tax return applicable to resident
individuals-Form No. 1
Form of income tax return applicable to partner
ships-Form No. 1A
Form of income tax return for the use of non-resident individuals resident outside the British EmpireForm No. 1C
Form of income tax return for the use of non-resident
individuals resident in the British EmpireForm No. 1D
INDEX
67

CHAPTER I
GENERAL
1. Income tax is charged in respect of the profits and income
(a) wherever arising, in the case of a person resident in
Ceylon, and
(b) arising in or derived from Ceylon, in the case of
every other person.
The phrase “profits and income arising in or derived from Ceylon includes all profits and income derived from services rendered in Ceylon, or from property in Ceylon, or from business transacted in Ceylon, whether directly or through an agent.
Basis of Liability
2. The income tax year commences on 1st April and ends on the following 31st March. For this year the tax payable is based on the profits and income which arose during the preceding year, i.e., for the income tax year 1941-42 tax is payable on the profits and income which arose during the year 1st April 194o to 31st March 1941. This is the normal basis. There are circumstances in which this basis is not adopted, and such departure from the normal basis is dealt with in paragraph 9.
Disclosure of Liability
3. On 1st April each year all persons known to the department as possibly having income chargeable with tax are furnished with printed forms in which to declare their

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income. If by 3 oth June a person who has income chargeable with tax has not been furnished with a form, it is his duty to give notice to the Commissioner, within fourteen days thereafter, that he is so chargeable. If he fails to do so he will be guilty of an offence and be liable on summary trial and conviction by a Magistrate to a fine not exceeding Rs. Soo. The Commissioner, however, has power to compound any such offence.
Liability of Residents
4. The term “person' includes a company, any body corporate, any society of persons whether corporate or unincorporate, and any Hindu undivided family. In the case of an individual resident in Ceylon, he is not liable to pay tax unless his total assessable income for the year exceeds Rs. 2,4oo. The phrase “assessable income’ is used for the first time and the reader is advised to refer to Chapter IX in which he will find how “ assessable income ” is arrived at. Under the Income Tax Ordinance the income of a married woman is deemed to be the income of her husband and therefore in determining whether he is liable to pay income tax a married man must also include in his income the profits and income of his wife. A common mistake made by individuals whose total income is just under Rs. 2,4Oo is to leave out of reckoning the net annual value (see Chapter VII) of their residence if they live in their own house. They overlook that when they live in their own house they are in effect paying rent to themselves.
Estimated Assessments
5. In the case of a person who has not disclosed his liability and/or has not furnished a return of income, the

( 3 )
Assessor may estimate the amount of assessable income of such person and assess him accordingly. This, however, does not preclude the Commissioner from taking legal action against such person for his failure to report liability or to furnish a return of income.
Authorised Representative
6. A tax-payer who has neither the time nor the inclination to conduct his income tax affairs himself may deal with the department through an “authorised representative.’ In the case of an individual an “authorised representative’ may be-,
(a) an accountant approved by the Commissioner; (b) an advocate or proctor;
(c) an employee regularly employed by the person
concerned; or
(d) a relative.
Exemptions
7. Among incomes exempt from tax are the following :-
(a) the income of any institution or trust of a public
character established solely for charitable purposes;
(b) the income of any religious body or institution whether established under any instrument in writing or not;
(c) the annual value of any place of public worship
and its premises;
(d) wound and disability pensions granted to mem
bers or ex-members of His Majesty's Forces;
(e) any capital sum received by way of retiring gratuity (other than a sum received in commutation of pension) or death gratuity or as consolidated compensation for death or injuries;

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(f) interest paid to an individual in respect of Ceylon
Savings Certificates;
(g) interest paid or credited to an individual on deposits with the Ceylon Savings Bank and the Ceylon Post Office Savings Bank;
(h) interest on any Ceylon Government loan issued
prior to Ist April 1932.
Classification of Income
8. For levying income tax, income is classified under the following heads, and in the printed forms issued to individuals, both resident and non-resident, cages are provided to return income classified under these heads:-
Agriculture,
Employment,
Trade, Business, and Profession,
Interest,
Ceylon dividends,
Dividends, etc., from the United Kingdom and India,
Dividends, etc., from countries other than Ceylon,
United Kingdom, and India,
Annual Value of Residence,
Rents, Other Profits.
Basis Other Than Normal Preceding Year
9. The following are cases in which the normal preceding-year basis is not adopted for the computation of statutory income:-
(a) A person who usually makes up the accounts of a trade, business, profession, etc., to some day other than the 3Ist March is allowed by the department to compute the income from that source on the profits of the year ending on that day in the year preceding the year of assessment.
(b) If a person commences a trade, business, profession, or employment, say, on Ist June 1941, his statutory income

( 5 )
from that source for the assessment year 1941-42 is the income from 1st June 1941 to 31st March 1942. For the next assessment year 1942-43 his statutory income is the income from 1st June 1941 to 31st May 1942. For each subsequent year from 1943-44 the statutory income is the income of the preceding year subject, of course, to paragraph 9 (a). If, however, the person ceases to exercise the trade, business, or profession, say, on 31st May 195o, the statutory income of the year 195o-5 I is the income of the two months Ist April to 31st May 195o. For the year of assessment immediately preceding that in which the cessation takes place, viz., 1949-50, the statutory income from this source is either the income of the year 1st April 1948 to 31st March 1949 (subject to paragraph 9 (a)) or the income of the year Ist April 1949 to 31st March 195o, whichever is the greater.
(6) Section II (5) of the Ordinance extends a concession to a person who has commenced a new trade, business, etc. Assuming that a business commenced on Ist August 1940, under the foregoing paragraph the liability from this source would be
I 94o-4 II ... Income from I.8.4o to 3 I.3.4I, I94 I-42 s I.8.40 to 3 I.7.4 I, I942-43 0 0 e. ss I.4.4I to 3I.3.42,
What section II (5) says is that for the second and third years of assessment after the commencement of a trade, business, etc., i.e., in this case for 1941-42 and 1942-43, the liability must be on the profits of the period 1st April 1941 to 31st March 1942 and Ist April 1942 to 31st March 1943 respectively, if these happen to be lower than the profits of the period Ist August 1940 to 31st July 1941 and Ist April 1941 to 31st March 1942, respective

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(d) If a person becomes a resident on a day within a year of assessment, his statutory income for that year of assessment from all sources other than trade, business, profession, vocation, or employment (which are dealt with in (b)) is the income from that day to the end of the year of assessment, and the statutory income for the following year of assessment is the income for one year from that day. For each subsequent year of assessment, the statutory income is the income of the preceding year. If a person ceases to be resident in any year of assessment, the statutory income for that year from the sources referred to is the income from 1st April to the day on which he ceases to be resident. This, however, does not apply to any source of profit retained by such person after he ceases to be resident. Income from such a source is assessed on the normal preceding-year basis, but he is taxed as a resident from 1st April to the date on which he ceases to be resident and thereafter as a nonresident.
(e) If a person dies, his statutory income for the year of assessment in which death occurs is the income of the period beginning on 1st April of that year and ending on the day of death. From the date of death the liability is that of the executor, and this is dealt with in Chapter XV.
10. The following are a few examples to illustrate the
somewhat confusing bases of assessment contained in paragraph 9 :-
4 is a Government servant retiring on 1st August
1941. His statutory income from employment for the
year of assessment 1941-42 would be
Salary from 1.4.41 to 3I.7.4I, Pension from I.8.4I to 31.3.42, Commuted pension, if any.

( 7 )
For the assessment year 1942-43 his statutory income would be pension from 1st August 1941 to
31st July 1942.
For the assessment year 1940-41 the liability would be on salary from Ist April 194o to 31st March 1941 or on that from Ist April 1939 to 31st March 1940, whichever is the greater.
B is a European planter resident in Ceylon for a number of years. He retires from planting with effect from Ist August 194I and decides to leave Ceylon. His income for the year ended 31st March 194o taxed in I 94o-4 II, consisted of—
Agriculture (tea estate), Salary, Profession (Visiting Agent), Ceylon Interest, Ceylon Dividends, United Kingdom Dividends.
He proposes to sell all his Ceylon shares. The tea estate is not to be sold and the money's lent on interest are not to be called back.
His liability for 1941-42 is as follows :-
Income from
Agriculture 8 då o . . . I.4.4O to 3 I.3.4. I, Salary s ... I.4.4I to 3 I.7.4I, Profession... s is . . . I.4.4 to 3 I.7.4I, Ceylon Interest ... . . . I.4.4O to 3 I.3.4. I, Ceylon Dividends . . . I.4.4 I tO 3 I. 7.4 II, U.K. Dividends ... ... I.4.4 I to 3 I.7.4 II,
For I940-41 he would normally have been taxed on income from all sources for the year ended 31st March 194o. This assessment would be allowed to remain undisturbed unless his income from salary and profession from Ist April 194o to 3Ist March 1941 happened to be greater than that for the period 1st April 1939 to 31st March 194o in which event the

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income from these sources for the former period would be substituted for the income for the latter period and an additional assessment made.
C is an individual resident in Ceylon. He dies on 31st July 1941. His sources of income are
Agriculture, Profession, Ceylon Interest, Rents.
His liability for 1941-42 is as follows :-
Income from
Agriculture 48 d 4 ... I.4.4 I tO 3 I. 7.4 II, Profession... s ... I.4.4I to 3 I.7.4I, Ceylon Interest ... ... I.4.4I to 3I.7.4I, Rents 0 . . . I.4.4 I tO 3 I.7.4 II,
As regards 1940-41, the assessment made on the basis of the year to 31st March 194o would not be changed unless the income from agriculture and/or profession for the year ended 31st March 194I exceeded the income from these sources for the year ended 31st March 194o in which case an additional assessment would be made for the difference.

CHAPTER II
AGRICULTURE
11. In the form of income tax return the cage for agriculture is divided into two sections (a) and (b). (a) is meant for income from estates under permanent crops such as tea, rubber, and coconut, while (b) is for income from paddy, tobacco, etc.
Mature Area, Immature Area, New Clearing S.
12. For each estate a separate Income and Expenditure Account is necessary. The income and expenditure of each estate should be prepared in three sections
(I) income and expenditure of mature area,
(2) income and expenditure of immature area,
(3) expenditure on new clearings (which is all capital expenditure and therefore not allowable as a deduction).
13. In the case of immature area the excess of expenditure over income is not always allowable as a deduction in full. The net expenditure on immature area of all the estates of a tax-payer is allowable subject to a maximum of 15 per cent. of the net income from mature areas of all the estates.
14. In allocating expenditure between mature and immature areas the cost of manure, labour, and all sundry
B ( 9 )

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expenses can be charged accurately to each area. Overhead expenditure like superintendent's salary should be charged proportionately on an acreage basis.
15. In computing the income of small estates the owners of which do not keep separate accounts for mature and immature areas, the Assessor allocates the expenditure on immature area on a pro rata acreage basis.
Expenses
16. Some of the expenses which tax-payers erroneously claim are survey fees, litigation expenses (except those connected with the recovery of income), and the cost of erecting new buildings (large or small). Renewals of buildings are allowed, provided that that part of the cost which represents improvements is capital and therefore not allowable. Depreciation on estate plant, machinery, and fixtures is allowed. (See paragraph 45).
Proceeds of Sale of Coupons
17. The proceeds of sale of coupons are income. In the case of estates which are on a care-and-maintenance basis, sales of coupons effected in any accounting year should be shown in full in the revenue account of that year. In the case of estates which sell tea and rubber with their own coupons and (a) purchase coupons from outside to sell their excess produce, and also (b) use for the sale of their produce their own coupons relating to a subsequent accounting year, the cost of (a) and the market value of (b) are allowed, but the value of (b) should be credited in the subsequent year's accounts under sales.

Travelling
18. Section Io of the Income Tax Ordinance reads as follows :-
“For the purpose of ascertaining the profits or income of any person from any source, no deduction shall be allowed in respect of
(a) domestic or private expenses, including the cost of travelling between residence and place of business or employment;
LSL S S LSL L LL SS LS LS S LS S S LS SL L LLSLL LSL LLS LS LSSS S LSS LSS LSLS LLL LLL LLLL LL LS LSLL LS SS S LSL S S LSLS LL L0SL LLLL 0 S SS SS SS LLL LL LLL LLLL LLLL L L LS LSS S LSS LS SLL 0
99
4 K X -X X KO « O 40 SL LSL S L S L L L SL S L S LSL SS LL LL LL LL 0SL LSL LSL SLL LS S S SL S S S S SSL S L 0S S S S LSL LSL LSL L L L L LSL LSL LSL LL LS LS 0S 0
The term “business’ has been defined in the Ordinance as including an agricultural undertaking. Therefore when the owner of an estate leaves his residence and goes to inspect or supervise the work of his estate he goes to his “ place of business,' and under the section quoted above the expenses of such travelling cannot be allowed as a deduction from the income of the estate. In Rajapakse vs. Commissioner of Income Tax (36 N.L.R. 258) the Supreme Court held that the expenses of travelling between his house and the Law Courts claimed by an advocate who resided in Colombo and had his chambers in his house did not come within the provisions of the section quoted above. This decision rests on the ground that the advocate’s “place of business’ is the room or rooms in his house set apart for professional purposes. Similarly, owners of large estates who have actually set apart a room or rooms in their houses as an office, in which books of accounts are kept, dealers interviewed, and sales effected, can claim the expenses of travelling to estates from their offices. Owners who do not fulfil this condition cannot legally claim such expenses. Owners of more than one estate can, however, claim the expenses of travelling from one estate to another.

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CHAPTER III
EMPLOYMENT
What Are “Profits from Employment” p
19. “Profits from employment' includes salary or wages, leave pay, fee, pension, commission, bonus, gratuity or perquisite; any sum received in commutation of pension; rental value of place of residence provided rent-free by the employer; the excess of the rental value over the rent paidthis occurs mostly in the case of bungalows occupied by Government officers; any other allowance granted in respect of employment whether in money or otherwise.
Leave Pay
20. Before the Amending Ordinance No. 25 of 1939, which came into force on 17th June 1939, was passed the leave pay granted by a non-resident employer to an employee who left Ceylon on the termination of his service in Ceylon was not taxable for the period commencing from the date of his departure, as it was deemed to be a payment by one non-resident to another non-resident. Under the amended law, “ leave pay' is included in “profits from employment,' and “any employment carried on or exercised by any person whether resident or non-resident shall not be deemed to cease by reason only of the grant of leave to that person.” This means that, in the case of employees of banks and non-resident companies who leave Ceylon for good on the termination of their service in Ceylon, the leave salary paid after their departure from Ceylon is now taxable. If the leave salary granted is in respect of a term of service
( I2 )

( 13 )
both elsewhere and in Ceylon, the amount of salary taxable in Ceylon is in the proportion of the service in Ceylon to the whole term of service in respect of which the leave is granted. W
Rental Value of free house
21. The rental value of houses situated outside rating areas (see paragraph 42) shall not be more than twenty-five per cent. of the total of salary, fee, bonus, commission, etc. By arrangement with planting interests the department assesses the rental value of estate bungalows at ten per cent. of the salary, bonus and commission subject to a maximum of Rs. 1,8oo per annum; if, however, any case is brought to notice in which the accommodation and amenities of the bungalow are not commensurate with the rental value arrived at by this method, the department is not averse to making a reduction after due enquiry.
Commission and Bonus
22. Commission is part of the remuneration which the employer has contracted to pay the employee. It is of course a variable amount, depending, for instance, in the case of planters, on the state of the market for agricultural produce and the successful conduct of business. It arises and accrues day by day and the aggregate amount payable for the year arises on the last day of the account year. Bonus, on the other hand, is a gift of a voluntary nature and arises on the date on which the employer sanctions it. This is a point which employees should bear in mind. It sometimes happens, especially in the case of estate employees, that the commission and the bonus which should be declared in any year's income tax return are not in respect of the same

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season. In the return for the year of assessment 1941-42 the profits from employment of the majority of planters would be
Salary ... April 1940 to March 1941 ; Commission for the year ended 31st December 194o;
Bonus ...... Company meetings generally take place in March, and bonus for 1941-42 assessment would be for 1940, sanctioned in March, I94I.
Withdrawals from Provident Fund
23. Amounts withdrawn from “approved provident funds during the year are taxable as “profits from employment' and should therefore be declared in the return.
Travelling Allowance
24. Travelling allowance is not taxable as it is deemed to be fully spent. There may be cases in which the travelling expenses incurred are in excess of the allowance granted, and in such cases the excess or part of the excess claimed may be allowed by the department provided proof is forthcoming that the allowance paid is meant to cover only part of such expenses and that the salary paid includes an addition for travelling.
Retirement from Service
25. Retiring from service and commencing to draw pension are regarded as the cessation of one employment and the commencement of another. For the basis of liability for the year of assessment in which retirement takes place and for the rate at which commuted gratuity is taxed, see paragraphs Io and 79.

CHAPTER IV
TRADE, BUSINESS, PROFESSION, ETC.
26. The net profit from trade, business, profession, etc., carried on individually and in partnership should be entered in the form in cages A3 and A4 respectively. Trading and Profit and Loss Accounts in the case of trade, and Income and Expenditure Accounts in the case of profession, should be attached to the returns. The expenses permissible are those broadly indicated in Chapter VIII. The accounts must be on an accrual basis in the case of trade and business, but in the case of profession the department usually accepts accounts rendered on a cash basis. If he adopts the cash basis, the tax-payer should show in his accounts only what was received in cash, no matter to what year the income actually relates, instead of including as income the whole amount earned and claiming as expense the bad and doubtful debts.
27. Owners of businesses in which competent full-time accountants are not employed are advised to hand over their income tax affairs to accountants approved by the department for that purpose. They should be entrusted with the duty of drawing up a Trading and Profit and Loss Account and Balance Sheet, preferably after a full or part audit. This, of course, means the payment of a fee, but that expense is worth while incurring because this course would in the long run be in the interests of the tax-payer.
( IS )

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CHAPTER V
INTEREST
Basis
28. Cage As of the form is meant for intereston moneys invested on mortgages, or debentures, or promissory notes. Income from interest should be declared on the basis of the preceding year subject to paragraphs 9 (d) and 9 (e). The full amount which fell due should be declared whether received or not. If any part of the interest so declared has not been actually received, a statement to that effect should be made in the
return.
Interest in Arrear
29. The interest not received will not be included in the assessment. If in subsequent years this interest is received, an additional assessment will be made in respect thereof.
recoverable Interest
30. If any interest has been included in the assessment and tax paid thereon and if it be subsequently found that that interest is unpaid and cannot be recovered, the assessment which includes that interest may be reduced by the amount of the interest shown to be irrecoverable and the tax paid thereon refunded.
( Ι6 )

( 17 )
Deductions from Interest
31. No deduction of any sort is allowed from interest, such as bad debts, legal expenses, charges for collection,
etc.
Interest Received by Money-lenders
32. Interest received by money-lenders is treated as income from trade and should therefore be returned in cage A3 or A4 of the form of income tax return, as the case may require.

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CHAPTER VI
DIVIDENDS
33. The income arising from a dividend paid by a company in Ceylon, in the United Kingdom, or in any other part of His Majesty's dominions where the legislature has provided for relief in respect of tax on income charged both in that country and in Ceylon, is the gross dividend, i.e., where the income tax payable in these countries is deducted at the time of the payment of the dividend, the amount of the dividend returnable is the amount before the deduction is made; where no such deduction is made, the income arising is the amount of the dividend increased by an amount on account of such tax corresponding to the extent to which the profits out of which the said dividend has been paid have been charged with such tax.
Dividends Paid by Companies Resident in Ceylon
34. Income from Ceylon dividends should be shown in the return of income in the manner required in cage A7 and the total of net income and tax deducted should be cast in the last column. The gross amount of the dividends will be included in the assessment and the tax due calculated on the total income. From the tax so arrived at the amount of tax certified by the company as having been deducted from the dividends at the time these were paid will be deducted and the balance only demanded in the notice of assessment. If, however, the tax deducted from dividends is more than the tax found to be payable, the difference will be refunded.
( 18 )

( IS )
35. A resident individual who has furnished a return of income which includes a Ceylon dividend from which tax has been deducted at the source will be refunded the tax so deducted if his total assessable income is found to be below Rs. 2,4oo.
36. If a person has the upper half of a dividend warrant on which the tax deducted is certified and if he is not one who furnishes a return of income, his total income being far below the taxable level of Rs. 2,4oo, he may apply to the Commissioner for a refund of the tax so deducted.
Dividends paid by Sterling Companies which pay
Ceylon Tax
37. Some sterling companies operate only in Ceylon and consequently the whole of their income is subject to Ceylon tax. If a dividend from such a company is included in the return of a shareholder resident in Ceylon, the gross dividend will be further grossed by the addition thereto of tax paid in Ceylon at 1.8 per cent. and the amount so arrived at will be included in the assessment, Tax at 15 per cent. of the amount so included will be set off from the tax due from this person. Sterling companies are taxed at I 8 per cent. and hence the grossing is done at I 8 per cent. ; but the set-off of tax is only at I 5 per cent. because the rate of 18 per cent. includes 3 per cent. to compensate for loss of estate duty on sterling company shares as these are not subject to estate duty, and this 3 percent. is expressly excluded from the calculation of the set-off. There are other sterling companies which carry on business in Ceylon as well as in other countries and in such cases a part only of the profits from which the dividend is declared would have borne

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Ceylon tax. If a dividend from such a company is included in a resident shareholder's return, the department will add Ceylon tax at 1.8 per cent. to that part of the dividend which bears the same proportion to the whole dividend as the Ceylon income of the company bears to the total income from which the dividend is paid, and include the total amount thus obtained in the assessment. The assessee will be credited with tax at 15 per cent. of the grossed Ceylon share of the dividend.
Example :
A London company owns tea gardens in Ceylon
profits from which it declared a dividend was derived from Ceylon and Io per cent. from Assam. A Ceylon shareholder returned a net dividend from this company of C14o, tax deducted (6o.
Gross sterling dividend... . ... ... (2Oo
Ceylon share 8 w 8 ... Ք. I8օ Assam share · f. 2o Add Ceylon tax (a) 18% to Ceylon share :
I8o XIoo
---. - £2 I9. I O.3 Total dividend taxable is 4,219. Io. 3 -- (2 o
- (239. Io. 3
Rs. 3, 193
Set-off of tax due is 15% of (219. Io. 3
or Rs. 2,927 ... a a = Rs.. 439.o5
38. Dividends from sterling companies received by a non-resident individual are not regarded as income arising
in Ceylon.

CHAPTER VIII
RENT OF LANDS AND BUILDINGS
39. To determine correctly the income returnable from rent of lands and buildings thereon it is necessary to understand clearly the meaning of the following terms:-
(a) Annual Value,
(b) Net Annual Value, (c) Rental Value.
Annual Value, Net Annual Value and Rental Value
40. The assessment which a local authority fixes for the purpose of recovering rates is called the annual value. In Colombo and other principal towns, the annual value is twelve months' rent less rates. The net annual value of houses in these towns is arrived at by deducting from the annual value 20 per cent, thereof for repairs, etc. What is called rental value is twelve months' gross rent, i.e., the nett annual value plus the allowance deducted for repairs, etc., plus rates.
41. Each local authority has its own method of fixing annual value. In some towns the annual value is twelve months' rent less a percentage for repairs, no deduction being allowed for rates; in others it is twelve months' rent less rates less a percentage for repairs; in yet others it is twelve months’ rent without any deduction for repairs or rates. In arriving at the net annual value, the correct course is to work out the gross rent for twelve months on which the annual value is based and then to deduct the rates paid and 20 per cent. of the balance for repairs, etc.
( 21 )

Page 17
( 2.2 )
42. Income returnable from rent of lands and buildings in rating areas should be the rent received less rates less 20 per cent. of the balance for repairs, but should never be less than the net annual value, subject, of course, to proportionate reduction for periods during which the houses were untenanted. This requires explanation.
Example:
A house in Colombo is rated at Rs. 1,25o. This means that the owner is expected to get a monthly rental of Rs. 125. But he does not get it. He is able to get only Rs. II5 a month. In his return he will
Cter-----
Gross rent ..., w XX 4 ... Rs. II,38o Rates... w w • • • • • 2१०
Rs. I, I 3o Repairs (a) 20% ... A v ... , 226
Net Annual Value ... KS KO Y ... Rs. 9o4
The department will nevertheless tax him as
follows :-
Annual Value KO 40 & 8 w ... Rs. I, 2 So Repairs (a) 20%, ... Φ Χ 3 Ο . . . . 2 SO
Net Annual Value ... ... Rs. I,ooo
ಹಾ~
This is a source of discontent among owners of house property as they are compelled not only to pay the local authority rates based on a higher rental than they actually receive but also to pay income tax on income they have not received. As the law stands income tax must be paid on rents based upon assessment for rates, and the only means of avoiding the payment of tax on a higher rental than was

( 23 )
actually received is to appeal against the assessment of the local authority and bring it down to a figure based correctly on the rent recovered.
The net annual value of houses situated outside the limits of local authorities shall not, under the Ordinance, exceed five per centum of the capital value.
43. If a house is rented out for an amount which is below its net annual value, the owner is taxable on the rent received without any deduction and the tenant is taxable on the difference between the rent paid and the net annual value.
Example :
A house in Colombo is rated at Rs. I,ooo. The rent paid per mensem is only Rs. 6o, or Rs. 720 for
the year.
The net annual value isAnnual Value o v. 8 ... Ris. I, ooo Repairs (d) 20% ... di 4 4 . . . . 200
Net Annual Value ... ... Rs. 8oo
The difference between the net annual value and the rent paid is Rs. 8oo-Rs. 72O = Rs. 8o.
The owner is taxable on Rs. 72O, and the tenant on Rs. 8o.
44. Cage AIo of the form of return is meant for the net annual value of house or houses occupied or reserved for occupation by the person making the return. Cage AI I is for rents received.

Page 18
CHAPTER VIII
DEDUCTIONS
Allowable Deductions
45. In ascertaining the profits or income from any trade or business (which includes agriculture), profession, vocation or employment, the Ordinance lays down that “all outgoings and expenses incurred in the production thereof are allowable. Disagreements between tax-payers and taxing officers often arise on the question as to what is admissible expense and what is not. Each claim has to be judged on its merits, the only determining factor being whether the expense was incurred in the production of the income concerned. The following, however, are some of the expenses allowed by the Ordinance:-
(a) Depreciation by wear and tear of plant, machinery, and fixtures calculated at a fixed rate on the written-down value; depreciation is allowed only if the plant, etc., has been actually used during the year of account. If, for instance, a rubber estate is kept on a care-and-maintenance basis and the coupons are sold, no depreciation of plant, etc., is allowable. The rates of depreciation are given in the Income Tax Manual.
(b) Loss occasioned by selling or discarding any plant, etc., which represents the excess of the written-down value over the sum, if any, realised by the sale. Provided that if the sale results in a profit such profit has to be included in the revenue account.
( 24 )

( 25 )
(c) Cost of repairs to plant, etc., and the cost of renewal or repairs to premises, implement, utensil, or article employed in the business. Provided that in the case of plant, machinery, or fixtures, renewal may be claimed instead of the depreciation and loss referred to in (a) and (b).
(d) Bad and doubtful debts. Provided that recoveries on account of bad and doubtful debts previously allowed are treated as receipts and brought to account.
(e) Interest paid or payable to a banker.
(f) Contribution payable by Government officers towards Widows' and Orphans' pensions.
(g) Contribution towards teachers' pensions.
(b) Contribution to a pensions, savings, or provident fund approved by the Commissioner.
Expenses Not Allowable
46. Some of the expenses not allowable are:-
(a) domestic or private expenses;
(b) expenses of travelling between residence and place
of business or employment;
(c) expenditure of a capital nature or any loss of
capital;
(d) cost of improvements;
(e) United Kingdom income tax, Ceylon income tax,
/ or Empire tax;
(f) any contribution to pensions, provident, or savings funds, other than those mentioned in
paragraph 45 (f), (g), and (h).

Page 19
CHAPTER IX
STATUTORY INCOME, ASSESSABLE INCOME,
AND TAXABLE INCOME
47. Before income tax is levied income is made to pass through three stages, viz., statutory income, assessable income, and taxable income.
Statutory Income
48. The amounts of income entered in the various cages of income tax forms after all allowable deductions therefrom have been made are called statutory income.
Assessable Income
49. From the total of the statutory income so arrived at further deductions are allowable under the following categories :-
(a) interest other than that referred to in paragraph
و(e) 45 (b) annuity, (c) ground rent, (d) royalty, (e) loss in business, trade, etc.
50. Deductions (a), (b), (6), and (d) are normally on the basis of the preceding year. If the bases of assessment are different (see paragraph 9), the deductions are for the period which forms the basis. These deductions are not allowable if the payments are made by one non-resident to another non-resident. Furthermore, if these payments have not been and will not be made, they will not be allowed as
( 26 )

( 27 )
deductions. These sums should be entered in cages B (1) to B (4) of the return-Form No. 1. At the foot of page 6 of that form is cage B. This cage should be filled up carefully as the allowance of the interest claimed depends upon the information furnished in this cage. If interest claimed is found to be unpaid the Assessor will normally not allow it. If such interest is paid later the tax-payer must make a written application to the Assessor within twelve months of the payment, furnishing proof of payment,
for a re-assessment of the income of the year in which the interest was not allowed. The Assessor will thereupon make a re-assessment regardless of any time-limit and refund the tax overpaid.
51. Deduction (e) is allowable mostly under section 13 (1)(c) and in some cases under section I 3 () (h).
If the loss under section 13 (1) (c) allowable against the statutory income of the first year of assessment after that in which the loss was incurred is too large to be worked off in that year, the balance may be carried forward and claimed in the following year or the following two years as the case may be. Any balance left at the end of the third year becomes time-barred. There is one peculiarity about loss, viz., that it is always allowed on the basis of the preceding year April to March or the year adopted for purposes of accounting.
Loss under section 13 (1) (b) is of a different character. If, for instance, the assessment for the year 1941-42 based upon the accounts of the preceding year 1940-4I results in tax payable but the tax-payer finds that his business during the year of assessment shows a large loss, he may claim that the loss incurred during the year of assessment be deducted

Page 20
( 28 )
from the assessable income for that year. If the tax-payer elects to do this, he must give notice of such intention in writing within six months of the end of the year of assessment, viz., in this case before 3 oth September, I 942. Any loss so allowed on the actual-year basis is, of course, not allowable again in the following year under section I 3 (1) ().
52. The balance of the statutory income after the foregoing deductions have been made is called assessable income.
Taxable Income
53. Taxable income is arrived at by deducting from the assessable income the allowances authorized in section 16. These allowances are given only in the case of resident individuals, which means that in the case of every “person' other than a resident individual the taxable income and the assessable income are the same.
54. The authorized allowances are
(a) Earned income relief, (b) Personal allowance, (c) Wife allowance, (d) Child allowance, (e) Dependent relative allowance.
(a) Earned income relief is an allowance from income derived by the personal exertion of the tax-payer. It is onefifth of the income from employment, profession, trade, business, or vocation, and one-tenth of the income from agriculture, after deducting any loss allowable. The total allowance, however, should not exceed either one-fifth of the total assessable income or Rs. 4,ooo, whichever is less.

( 29 )
(b) Personal allowance-Rs. 2,ooo.
(c) Wife allowance-Rs. 1,ooo, if the tax-payer had at any time during the preceding year a wife who was not living apart from him under the decree of a competent court or duly executed deed of separation.
(d) Child allowance-Rs. 1,ooo for the first unmarried child and Rs. Soo for each such subsequent child the taxpayer had at any time during the preceding year-the total allowance under this head not to exceed Rs. 3,ooo-provided that no allowance is due in respect of a child who
(i) was over eighteen years of age, or
(ii) had during the preceding year an income of
Rs. I,ooo, or
(iii) carried on or exercised during the preceding year a trade, business, profession, vocation, or employment. The term “child' includes a step-child but does not include an adopted or illegitimate child. If, however, a child was between eighteen and twenty-two years of age and was receiving full-time instruction at a college or other educational establishment, the allowance is due.
(e) Dependent relative allowance-Rs. 25o in respect of each relative who lived with and was maintained by the tax-payer throughout the preceding year. “Relative’ means a parent, brother, sister, or child, but does not include a child for whom allowance under (d) is claimed: provided that
(i) no allowance is due in respect of a relative who had during the preceding year an income exceeding Rs. 25 o;

Page 21
( 3o )
(ii) the total allowance under this head does not
exceed Rs. 1,eoo; and
(iii) the total of this allowance and the allowance under (d) does not in the aggregate exceed Rs. 3,ooo.
Proportionate Allowance
55. If a tax-payer is resident during only a part of a year of assessment the allowances under (b), (c), (d), and (e) are proportionate to the number of days the tax-payer was deemed resident in the year of assessment; and in the case of the allowance under (a) the relief on the earned income proportionate to the number of days the tax-payer was deemed resident should not exceed the figure of Rs. 4,ooo reduced in the same proportion.

CHAPTER X
PARTNERSHIP
56. The precedent partner of a firm is responsible to the Commissioner for furnishing returns of income of the partnership; if no active partner is resident in Ceylon, the return of income has to be furnished by the agent of the partnership in Ceylon.
Firm Not Assessable
57. A firm is not assessable as such. The share of profit or loss of each partner is computed and carried to his personal return and is assessable in his hands together with his income from other sources.
58. Partnership income is income from trade or business and consequently earned income relief is allowable on it unless, of course, the partner is a sleeping partner.
59. The return of income is for any period of twelve months immediately preceding the year of assessment for which accounts are kept subject, of course, to paragraph 9. Interest, annuity, ground rent, or royalty payable has to be deducted for the same period, before the income of the partnership is determined.
60. In computing the share of each partner's profit or loss, the salary drawn, interest on capital, etc., should be added to each partner's share.
61. The tax payable by a non-resident partner on the partnership income is recoverable from the partnership, or ( 31 )

Page 22
( 3.2 )
from a resident partner, or from the agent of the partnership in Ceylon.
62. Where no return of income has been furnished by a partnership or where the return of income furnished has not been accepted by the Assessor, an assessment of estimated income may be made on the partnership. This is done with a view to enabling the partnership to appeal against the assessment and to have the actual income of the partnership settled in appeal. If this method is not resorted to, as many estimated assessments as there are partners are necessary, followed by as many appeals.

CHAPTER XI
RESIDENCE
“Resident' Although Absent from Ceylon for Twelve
Months
63. An individual who has been resident throughout a period of twenty-four consecutive months can be out of Ceylon and yet be deemed a resident provided he is not continuously absent from Ceylon for an unbroken period of twelve months. If his absence exceeds twelve months, he is deemed non-resident from the date on which such absence commenced.
Six Months' Stay in Ceylon Required Before an Indivi
dual is Deemed a “Resident'
64. To be deemed “ resident’ an individual who arrives in Ceylon for the first time must remain in Ceylon for a period or periods aggregating to six months during the year commencing from the date of his arrival and if he is in Ceylon at the end of that year he is deemed resident throughout that year. If he is out of Ceylon at the end of that year, but his absence from Ceylon from the date of last departure is for a period less than three months he is yet deemed a resident for the whole year. If his absence is for a period longer than three months he is deemed a resident from the date of first arrival till the date of last departure and nonresident thereafter.
( 33 )

Page 23
( 34 )
65. If an individual who has been resident in Ceylon for two or more consecutive years leaves Ceylon permanently but dies within twelve months of his departure, according to what has been stated above he remains a resident up to the date of death. If in such a case the tax payable by the deceased person for the period from 1st April up to the date of death exceeds the tax which would have been payable if he had continued to live and become a non-resident, the Commissioner may direct that, as a measure of relief, he be assessed as a non-resident for such period.

CHAPTER XII
SEPARATE ASSESSMENTS
Income of Wife is Income of Husband
66. If a married woman is not living apart from her husband under the decree of a competent court or duly executed deed of separation, normally her income is deemed to be the income of her husband and is taxed accordingly. It is, however, open to a husband or wife to give notice in writing to the Commissioner before the 1st of June in any year of assessment requesting that tax on their incomes for that year of assessment be assessed and recovered separately.
67. It is not necessary that notice should be given each year. If separate assessments are desired until further notice, the Commissioner may be so informed.
68. If the Commissioner finds it difficult to collect from the husband the tax on the joint income, he has power to collect from the wife that portion of the tax which is due in respect of her income.
Resident Spouse Agent of Non-Resident Spouse
69. If one spouse is a resident and the other nonresident, the resident spouse is deemed to be the agent of the non-resident spouse for all purposes of income tax, including the payment of the tax whether assessed jointly or separately.
( 35 )

Page 24
( 36 )
Both Spouses Resident
70. Separate assessments may be desired for personal reasons, but this does not mean any reduction in the amount of tax payable because, whether assessed jointly or separately, the tax payable is the same. On the other hand, there is the possibility of the total tax on separate assessments being higher than the tax on the joint income as, for instance, in cases in which the “loss' claimed by one spouse is larger
than the statutory income of that spouse.
Examples:
(I) 4's income is as follows:-
Employment... wo Y ) 8
Rent ... 0 - O o a o O
...Rs. I8,ooooo
9 8.
99
3,ooo'oo
His wife's income is Rs. Io,ooo from agriculture. They have three children in respect of whom allowances
...Rs. Io,ooooo
P ps
• • 4 yy
are due.
The joint assessment would beAgriculture ... ... 0 0 a Employment... ... ep 9 Rent ... . . . . . .
Less Earned Income Relief...Rs. 4,ooo. oo Personal Allowance ... , 2,ooooo Wife Allowance ... , I,OOO' OO Child Allowance . . . . 2OOO “ OO
Taxable Income ..
Tax: Rs. 6,ooo (a) 7% ...Rs. 45 o' oo Rs. I6,Ooo () I 5 % ... , 2,4oo oo
Rs. 2,85 o • oo
Rs.
.Rs.
I8,ooo oo 3,ооо * оо
3 I,OOo ' Oo
9,ooo'oo
22,ooo'oo

( 37 )
4's assessable income is Rs. 2 I,ooo.
His wife's assessable income is Rs. Io,ooo.
4 will be assessed as follows :-
Assessable Income ... d is 0. ...Rs. 2 I,ooo • oo Les Earned Income Relief
8,ооо
Rs. 4,Ooo X = Rs. 3, I 3o‘ oo
23,OOO
Personal, Wife, and
Child Allowances
2 IOOO
RS, 5,၀၀၀x = , 3,387' oo , 6,5 I 7* oo
Taxable Income .Rs. I4,483 - oo
His wife will be assessed as follows :-
Assessable Income ... v ...Rs. Io,ooo'oo Les Earned Income Relief.
OOO Rs. 4,ooo X 5 = Rs. 87o• oo
23,OOO
Personal, Wife, and
Child Allowances
IO,OOO
Rs. 5,ooox = , I,6 Ι3 Oο 2,483*oo
3 I,ooo
Taxable Income ...Rs. 7,517 oo
Tax : 4's share
v0 -/0 س - 483و14 Rs. 6,ဝဝဝ x =Rs. 3,95o (a) 7%= Rs. 296 25 Balance Rs. Io,533 G). I5%= , 1,57995
Rs. 1,876. 20
ܡ̈ܣܒܝ̈ܣܘ̈ܗܒܒܝ̈ܫܒܗ

Page 25
( 38 )
His wife's share
757. R. 0/-
Rs. 6,00ంx=Rs. 2,oso (a) 7%= Rs. 15375 Balance Rs. 5,467 டு 15%= , 82o os
Rs. 973 - 8o
Rs 1,8762o--Rs. 9738o-Rs. 2,85o.
Note.--To enable the reader readily to follow the foregoing calculation, especially the manner in which earned income relief and other allowances given in the joint assessment have been apportioned between the husband and wife in the separate assessments, sections 22 (1) and 22 (2) of the Income Tax Ordinance are quoted hereunder:-
“ 22. (II) Notwithstanding the provisions of section 21, any husband or wife may give notice in writing to the Commissioner before the first day of June in any year of assessment requiring that tax for that year shall be assessed, charged, and recovered separately on the income of the husband and on the income of the wife as if they were not married, and all the provisions of this Ordinance shall thereupon apply to each of them accordingly.”
“ 22. (2) Where tax is assessed separately as a result of a notice under sub-section (1), the incomes of the husband and the wife shall be aggregated for the purpose of the allowances from assessable income under Chapter VI and for the purpose of calculating the sums chargeable at the unit rate and at twice the unit rate, and the total tax payable in respect of the incomes of husband and wife shall not be less than the amount which would have been payable if no notice had been given under this section.

( 39 )
“The allowances under Chapter VI and the amounts chargeable at the unit rate and at twice the unit rate shall be apportioned between the husband and the wife by the Commissioner in his discretion, the allowance in respect of earned income being apportioned by reference to the amount of the earned income of each, the other allowances from assessable income in proportion to the assessable income of each, and the amounts chargeable at the unit rate and at twice the unit rate in proportion to the taxable income of each :
* Provided that where an assessment is reduced or increased after such apportionment has been made, the Commissioner shall make a fresh apportionment, and any consequent adjustment shall be made by additional assessment or reduction or repayment of tax, as the case may require.'
Earned income of the husband is... ...Rs. I8,ooooo
Earned income of the wife is half of Rs. Io,ooo, as income from agriculture is regarded as earned income only to the extent of one half ... ... . SOOO ”OO
Total ... Rs. 23,ooooo
ܒܡܣܡܚ̈ܒܗܒܒ̈ܗ̄ܣ
Earned income relief given in the joint
assessment is the maximum ... ...Rs. 4,ooo'oo
8,ооо
23,ood
Relief to the husband is Rs. 4,ooox
5,ooo
Relief to the wife is Rs. 4,Ooo X
23,OOO
Other allowances given are in proportion to the assess
able income of each.
he husband R 2 I, ood
... SOOO Due to the husban S. So ^ 3r,ဝဝဝ
OOOO Due to the wife ... Rs. 5,ooox
3 I,ooo

Page 26
( 4o )
(2) B's income is as follows :-
Employment... ( ...Rs. 2o,ooo'oo Interest 4 a 曾始 曾 o o v ... , 3,6oo * oo
His wife's income from rent is Rs. 2,ooo, but she has loss on agriculture of Rs. 5,ooo.
Joint Assessment
Employment... ... O ...Rs. 2o,ooo'oo Interest w v A 4 ... , 3,6oo * oo Rent . s d 0 (a «H» QY a . . . . 2: OOO " CO
Rs. 2 5,6oo• oo Loss on Agriculture ... , 5, OOO' OO
Assessable Income ...Rs. 2o,6oo· oo
Less Earned Income Relief Rs. 3,ooo. oo Personal Allowance ... , 2,ooo-oo Wife Allowance ... ,, I,OOo‘ Oo ,, 6,ooo‘ oo>
Taxable Income ...Rs. I4,6oo· oo
Tax : Rs. 6,ooo () 7% ...Rs. 45 o' oo Rs. 8,6oo (a) I5% ... , 1,29O' Oo
Rs. I,74o • oo
Separate 4ssessments
B's assessable income is Rs. 23,6oo.
His wife's assessable income is nil, as when the loss of Rs. 5,ooo is deducted from Rs. 2,ooo the result is a munus quantity.

( 41 )
The tax is therefore due only from the husband, and it amounts to Rs. 2,04o as follows :-
Assessable Income ... QO A o 0. ...Rs. 23,6oo * oo
Les Earned Income Relief Rs. 4,ooo. oo Personal Allowance ... , 2,ooooo Wife Allowance ... , Iooo'oo , 7,OOO'00
Rs. I 6,6oo • oo
ܡ̈ܡܡ̈ܫܵܒܒܵܒܒܗ̄
Tax: Rs. 6,ooo (a) 7% ...Rs. 45 o' oo Rs. I o,6OO (@) I 5% ... ,, I,59O‘ Oo
Rs. 2,o4o• oo
One Spouse Resident and the Other Non-Resident
71. If the husband or wife is non-resident, the resident spouse may give notice of separate assessment and ask therein that under section 22 (3) the income from Ceylon of the non-resident spouse be deemed to be the income of the resident spouse. If this is done the resident spouse will be taxed on his or her income from sources both in Ceylon and out of Ceylon plus the income of the non-resident spouse from sources in Ceylon. The allowances which are given in this assessment are earned income relief, personal allowance, and dependent relative allowance. Wife allowance and child allowance are not given. This method of assessment is advantageous in cases in which the nonresident spouse has large income outside Ceylon.
Example:
C’s income is salary Rs. 15,ooo. His wife is a non-resident and has the following
income :- Ceylon interest W II e O UN ...Кs. 3,оод* оо United Kingdom dividends ... , 8,ooo'oo
They have one child.

Page 27
( 4.2 ) Joint 4 sessment
Assessable Income ... a 's ...Rs. 26,ooooo
Les Earned Income Relief Rs. 3,ooo. oo Personal Allowance ... , 2,ooooo Wife Allowance ... , I,OOO' OO Child Allowance ... ,, I,OOo‘ OO », 7,Ooo‘ Oo
Rs. I9,ooooo
Tax: Rs. 6,ooo (a) 7%, ...Rs. 45 o' oo Rs. I 3,OOo (@) I 5% ... ,, I,9 5 o‘ Oo
Rs. 2,4oo • oo
Separate Assessment under Section 22 (3)
Assessable Income ... a 8 ...Rs. I8,ooo'oo Less Earned Income Relief Rs. 3,ooo-oo
Personal Allowance ... , 2,ooooo 5,ooo'oo
Rs. I3,ooooo
Tax: Rs. 6,ooo (a) 7% ...Rs. 45 o' oo Rs. 7,OOo (@) I 5% ... ,, I,o 5 o‘ oo
Rs. I,5oo • oo
Tenman

CHAPTER XIII
RATES OF TAX
72. An individual resident in Ceylon has to pay tax on his taxable income at the following rates :-
Upon the first Rs. 6,ooo ... the unit rate ; Upon the next Rs. 3o,ooo ... twice the unit rate; Upon the remainder ... three times the unit rate.
Provided that if an individual is taxable as a resident only for a part year, the said sums of Rs. 6,ooo and Rs. 3o,ooo are reduced in the same proportion as the number of days during which he is resident bears to the number of days in the year of assessment.
73. If the taxable income of a resident individual for a year of assessment is nil, or if the tax chargeable at the unit rate on the taxable income is less than one per cent. of his assessable income, the tax payable by that individual is one per cent. of his assessable income. Provided that the difference between the tax payable by a resident individual and his assessable income is never less than Rs. 2,4oo.
Examples :
(1) 4's assessable income is Rs. 2,5oo. His allowances aggregate to Rs. 3,ooo. His taxable income is therefore nil. As his assessable income is more than Rs. 2,4oo, his liability is 1% of Rs. 2,5oo, i.e., Rs. 25.
(2) B's income is as follows :- Employment W» «8 o ... ... Rs. 3,ooo'oo Rent ... R ... , I,OOO'OO
Assessable Income ... Rs. 4,ooooo
( 43 )

Page 28
( 44 )
Allowances :
Earned Income Relief ... Rs. 6oo oo Personal Allowance ... , 2,OOO ' OO Wife Allowance ... ... ,, I,oOO‘ Oo ,, 3,6oo‘ oo
Taxable Income ... Rs. 4oo' oo
Tax (o) 7% of Rs. 4oos-Rs. 3o. But the tax of Rs. 3o is less than 1% of Rs. 4,ooo. Therefore the correct liability is 1% of Rs. 4,ooo, i.e., Rs.. 4o.
(3) C's assessable income is Rs. 2,418. His allowances amount to Rs. 3,ooo. Taxable income is therefore nil. Tax at 1% of assessable income is Rs. 24, 18. But if the tax of Rs. 24. I8 is deducted from the assessable income of Rs. 2,418 the balance is less than Rs. 2,4oo. Therefore the correct liability is Rs. 2,4I8-Rs. 2,4oo, i.e., Rs. 18.
74. An individual not resident in Ceylon has to pay tax on his taxable income at the following rates:-
Upon the first Rs. 5o,ooo twice the unit rate;
Upon the remainder ... three times the unit rate: Provided that where a non-resident individual is taxable as a non-resident for a part year only, the said sum of Rs. So,ooo is reduced in the same proportion as the number of days during which he is non-resident bears to the number of days in the year of assessment.
75. Companies registered in Ceylon pay tax at twice the unit rate on the whole of their taxable income.
76. Companies not registered in Ceylon and Hindu undivided families pay tax at twice the unit rate plus an additional three per cent, on the whole of their taxable income.

( 45 )
77. Mutual insurance companies, whether resident or non-resident, pay tax at the unit rate.
78. The tax payable by all other persons not dealt with in the foregoing is at twice the unit rate.
79. Commuted pensions are taxed at a special rate. This rate is obtained by dividing the tax paid for the year of assessment preceding that in which the officer retired by the assessable income of that year. The amount of the commuted pension taxed at the special rate is limited to the difference between (I) the taxable income arrived at from the assessable income inclusive of this pension, and (2) the taxable income arrived at from the assessable income exclusive of this pension. In the case of non-residents the assessable income is also the taxable income and hence the entire commuted pension is taxable at the special rate.
Example:
A retires on Ist July, 1941. His salary from Ist April 1941 to 3oth June 194I is Rs. 2,4oo. Pension from 1st July 1941 to 31st March 1942 is Rs. 3,6oo;
commuted gratuity Rs. I6,ooo; agriculture Rs. 1,5oo; rent Rs. 2,ooo. He has a wife and one child.
His assessment without including the commuted gratuity is
Agriculture 0 8 o o ... Rs. . I,5Oo‘ oo Employment ... to ae V 8 ... , 6,ooo'oo Rent d P. ... , 2,OOO' OO
Assessable Income ... Rs. 9,5oo' oo
Les Earned Income Relief Rs. 1,35o oo Personal Allowance , 2,ooooo
Wife Allowance ... , I,ooooo Child Allowance ... , I,ooo' oo , 5,35 o' oo
Taxable Income ... Rs. 4, I 5 o' oo
--ண்

Page 29
( 46 )
His assessment including the commuted gratuity
is
Agriculture a 0. ... Rs. I,5Oo ‘ oo Employment - . . . . 22:OOO” OO Rent w SL LS LSL S S S SLSL LLLL LL . . . . 2OOO “ OO
Assessable Income ... Rs. 25.5oo oo
Les Earned Income Relief Rs. 4,ooooo Personal Allowance , 2,ooo. oo
Wife Allowance ... , 1,ooooo Child Allowance ... , 1,ooooo , 8,ooooo
Taxable Income ... Rs. I 7,5 ooʻ oo
The difference between Rs. 4,15o and Rs. 17,5oo, i.e., Rs. 13,35o, is taxable at the special rate. The special rate is arrived at as follows :-
The year of assessment preceding the year in which retirement takes place is 1940-41. The assessment for that year was:-
Agriculture ... . . ... Rs. I,4oo‘ oo Employment 8 4 o o af ... , 9,6ooo oo
Rent v 0 d . . . , 2OOO “ OO
Assessable Income ... Rs. 13,ooo. oo
Les Earned Income Relief Rs.2,06o' oo Personal Allowance , 2,ooooo Wife Allowance ... , I,ooo. oo Child Allowance ... , I,ooooo , 6,o6o' oo
Taxable Income ... Rs. 6,94o' oo
ܒܗܿܒܣܒܝܣܡܒܝ̈ܒ --ܡ̈ܝ ܀

( 47 )
Tax: Rs. 6,Ooo (a) 7% ... Rs. 45 o' oo
Rs. 94o @) I 5% ... ,, I4 I ‘ oo
Rs. 59I • oo
ܦܵܒܩܒܪܒܒܗ̄ܒܒ
59 I * oo
=A 0 55% '4 rooلايتونو
The taxable income of Rs. 17,5oo is therefore taxed as follows :-
Rs. 4, ISO G) 7% ... Rs. 3 II 25 Rs. 13,35oG) 4' 55%. , 60742
Rs. 918, 67
பண்-பண்ம்

Page 30
CHAPTER XIV
DEDUCTION AT SOURCE
Deduction by Resident Companies
80. Every resident company is entitled to deduct from the amount of dividend which becomes payable to any shareholder tax at twice the unit rate in force for the year preceding the year of assessment in which the sum is payable. This deduction is made for the purpose of enabling the company to transfer to the shareholders the tax which it has to pay on its profits. In the case of any particular shareholder the Commissioner may require the company to deduct from the dividend payable to that shareholder tax at a rate higher than twice the unit rate, but not exceeding three times the unit rate. The tax so deducted in excess of tax at twice the unit rate should be remitted to the Commissioner.
81. A company which deducts tax in the manner aforesaid must attach to the dividend warrant a statement showing
(a) the gross amount of the dividend;
(b) the rate and the amount of tax deducted; and (c) the net amount paid.
Deduction from Rent, Annuity, etc., Payable to Person
Out of Ceylon m
82. If any person in Ceylon pays or credits to any person out of Ceylon any sum falling due being
(a) interest on debentures, mortgages, loans, deposits,
or advances; or
(b) rent, ground rent, royalty, or annuity, which is payable either in respect of property in Ceylon or out of income arising in Ceylon,
( 48 )

( 49 )
whether such sum is due from him or from another person, he is entitled to deduct tax therefrom at twice the unit rate for the year preceding the year of assessment in which the sum falls due. The Commissioner may require that from the sums paid or credited to a particular person tax be deducted at a rate higher than twice the unit rate, but not exceeding three times the unit rate. The tax so deducted is payable forthwith to the Commissioner. Tax, however, is not deductible from any interest on any loan or advance made by a banker or on any interest paid out of income not arising in Ceylon.
83. The person who deducts tax in the manner aforesaid from any sum paid or credited to a person out of Ceylon should issue to such person a statement showing
(a) the gross amount of such payment;
(b) the rate and amount of tax deducted; and (c) the net amount actually paid.
84. If the assessable income of a person includes income from which tax has been deducted either under paragraph 8o or under paragraph 82 the tax so deducted and shown in the statement issued to him will be set off against the tax payable by him.

Page 31
CHAPTER XV
EXECUTORS
85. The statutory income of the executor of any deceased person from the estate of that person is as follows:-
(a) For the year of assessment in which the death occurs, the income from the date of death to the end of the year of assessment.
(b) For the year of assessment next following that in which the death occurs, the income for one year from the date of death.
(c) For any subsequent year of assessment, the income of the year preceding the year of assessment.
(d) For the year in which the distribution to the beneficiaries of the capital amount of their several interests in the estate is completed, the income from the first of April of that year to the day on which the distribution is completed.
86. Any part of the income of the estate received by, distributed to, or applied to the benefit of, any beneficiary during the period when the income of the estate is the statutory income of the executor, is deductible by the executor from such income. -
87. The statutory income of any beneficiary of the estate of a deceased person administered by an executor is the amount of profits or income received by or distributed to him or applied to his benefit during the year preceding the year of assessment.
( So )

( 5 I )
88. When the beneficiary of the estate of a deceased person has received the capital assets due to him, his profits or income from such assets is assessable on him on the normal preceding-year basis, provided that income from trade or business is taxed in the manner set out in paragraph 9 (b).
89. The executor pays tax at twice the unit rate on income of the estate remaining in his hands undistributed. If the income of the estate were fully distributed and taxed in the hands of beneficiaries, part of it might bear tax at more than twice the unit rate, part at less than twice the unit rate, and part might not be taxed at all, the rate of tax depending on the total assessable income of the beneficiary -wherefore in section 26 there is provision by which, after the capital assets of the estate are fully distributed, an adjustment could be made by which the department refunds to the beneficiaries any tax collected in excess or collects from them any additional tax due. The amount of such tax is the difference between (a) the tax paid by the executor in respect of the beneficiary's share of the income of the estate for the period extending from the date of death to the date on which the beneficiary received the capital amount of his interest in full plus the tax paid by the beneficiary, and, (b) the tax which would have been payable by the beneficiary if his assessable income for each year of assessment had included his full apportioned share of the income of the estate which arose in that year.
90. The executor of a deceased person is liable to tax for all periods prior to the date of death of that person. No assessment, however, can be made in respect of a period prior to the date of death after the expiry of two years from the date of death.

Page 32
CHAPTER XVI NON-RESIDENTS
Services Rendered Outside Ceylon
91. A non-resident person who is employed by a
resident person and performs services outside Ceylon is not
liable to pay tax on his income from that source.
Income for Past Services Rendered in Ceylon
92. A non-resident person who derives income from Ceylon for past services rendered in Ceylon is taxable on such income.
Non-Resident Individuals
93. If the assessable income for any year of assessment of an individual not resident in Ceylon consists solely of earned income and does not exceed one thousand rupees, such income is not taxable. This means that if the assessable income is wholly unearned or partly earned and partly unearned, it is taxable however small the amount may be.
Business Transacted on Behalf of Non-Resident
94. If a person in Ceylon acting on behalf of a nonresident person effects any insurance or sells any property whether in Ceylon or outside Ceylon and whether the moneys arising therefrom are paid to or received by the non-resident person directly or otherwise, the profits derived from any such insurance or sale are deemed to be profits derived by the non-resident person from business transacted in Ceylon and the person in Ceylon who acts on his behalf is deemed to be his agent for all purposes of the Ordinance.
( 52 )

CHAPTER XVII
TEMPORARY RESIDENTS
95. Visitors to Ceylon who come to spend a holiday are not chargeable with tax unless they spend six months in the Island and have become “resident.' If visitors perform services, for however short a period, whether for a Ceylon employer or non-Ceylon employer, they are taxable on the income earned, provided it exceeds one thousand rupees.
96. If a non-resident person visits Ceylon on contract with a resident person, the latter is the agent of the nonresident person and as such becomes liable to pay the tax due from such person. It is in the interests of the resident person therefore to see to it that the non-resident person settles his income tax liability before he leaves the Island.

Page 33
CHAPTER XVIII
PROVIDENT AND PENSION FUNDS
Provident Funds
97. If a provident fund is approved by the Commissioner under section 9 (1) (g) of the Income Tax Ordinance, the contribution made to such a fund by a member is allowed as a deduction from his income and the contribution made by the employer is also allowed as a deduction from his profits. If a member withdraws any portion of the moneys to his credit whilst being a member, the amount so withdrawn is added to his income and taxed. When he finally retires and seeks to withdraw the whole amount to his credit in the fund, the tax for which he is liable is deducted before the amount is paid to him.
98. No tax is due in respect of withdrawals by members whose services were performed outside Ceylon whether for a resident employer or a non-resident employer.
Pension Funds
99. What is said in paragraph 97 about contribution of employees and employers applies to pension funds as well. Pensions paid by resident employers are liable to tax wheresoever the recipient may be resident. If, however, the pension is paid to a non-resident member who has not rendered services in Ceylon even though for a resident employer, such pension is not taxable. Pensions paid by non-resident companies are taxed only if the members are resident in Ceylon.
( 54 )

CHAPTER XIX
DOUBLE TAX RELIEF
Double Tax Relief-United Kingdom Tax
Section 45 (1)
100. Any person (whether resident or non-resident) who has paid Ceylon tax for any year of assessment on any part of his income and has paid United Kingdom income tax for that year on the same part of his income is entitled to relief from Ceylon tax.
101. The relief would be the excess of Ceylon tax paid over half the United Kingdom tax paid on that part of the income which is taxed in the two countries. As the Ceylon rate of tax is less than half the United Kingdom rate, no relief is due at present from Ceylon. Whatever relief is due is from the United Kingdom.
102. In the case of Ceylon residents who return income which has borne United Kingdom tax and which under Ceylon law is also taxed in Ceylon, the department furnishes to the tax-payer, at the time the notice of assessment is served on him, a certificate to enable him to claim double tax relief in the United Kingdom.
Double Tax Relief-Empire Tax-Section 46
103. Any person who has paid both Ceylon tax and Empire tax for any year of assessment on income from any source is entitled to relief in Ceylon of one half of the Ceylon tax or Empire tax paid or payable on that income, whichever is the less.
( 55 )

Page 34
( 56 )
104. "Empire tax” means any income tax and super tax charged under any law in force in any part of His Majesty's dominions (other than the United Kingdom and Ceylon) including protectorates and mandated territories where the legislature has provided for relief in respect of tax charged on income both in that country and in Ceylon which appears to the Commissioner to correspond to the relief granted by section 46 (1). In practice this relief is given mostly to those who pay tax in Ceylon and in British India and in a few instances to those who have income taxed both in Ceylon and in Burma, or Australia, or New Zealand.
105. The departmental arrangement to enable taxpayers to obtain relief from “Empire tax' is as follows:-
British India and Burma.-A resident or non-resident who has paid both Ceylon tax and British Indian tax for any year of assessment on income from any source should first apply to the officer dealing with his income tax in the country in which he is resident, giving particulars of the income doubly taxed and forwarding at the same time, in proof of the tax paid in the other country, the notice of assessment and connected receipts where tax is paid by direct assessment and certificates of deduction where tax is paid by deduction at the source. The officer will thereupon grant the applicant the relief to which he is entitled and also issue to him a certificate stating what the amount of that relief is. That certificate, when produced by the applicant to the officer dealing with his income tax in the other country, will be accepted by the latter and the relief due given. Claims to any refund of double tax must be made in British India within one year from the last day of the year in which tax in British India or in Ceylon was recovered, whichever is later.

( 57 )
The income tax law of Burma is the same as that of British India and what has been stated in the case of a person who has paid Ceylon and British Indian tax applies to an applicant for double tax relief who has paid tax in Ceylon and in Burma.
4ustralia and New Zealand.-Under the Commonwealth law Australian residents who have income which has borne Ceylon tax are exempted from tax on such income. Consequently there is no question of double tax relief from Ceylon in respect of such income. Ceylon residents who have income arising in Australia and pay tax on such income are not given any double tax relief by the Commonwealth Government. If, however, such income is also taxed in Ceylon the tax-payer is entitled to relief from double tax in Ceylon. To obtain this relief the Australian notices of assessment and receipts for tax paid should be produced to the Assessor. No relief is due in respect of tax paid in the Australian States. *
The law of New Zealand is almost the same as that of the Commonwealth of Australia and what has been stated about persons who pay Ceylon tax and Commonwealth tax applies to those who pay tax on the same income both in Ceylon and in New Zealand. Relief Under Section 45 (2)
106. Non-resident individuals who derive income from Ceylon can be divided broadly into two classes, viz., those who derive income from pension or agricultural profits, and those who derive income from investments, e.g., dividends, interest, rent, etc. Those who receive pensions or agricultural profits are normally taxable by direct assessment at twice the unit rate, while those who receive invest
ment income are taxed at source alsoGsNegri rays, the

Page 35
( 58 )
non-resident individuals who are British subjects resident in the British Empire (which includes any British protectorate or protected state or any territory in respect of which a mandate on behalf of the League of Nations has been accepted by His Majesty) are entitled to certain relief from the tax so paid. To obtain this relief a special form (No. 1D) should be filled up by the tax-payer. Whenever a direct assessment has to be made the department sends out a copy of this form to the assessee. If this form duly completed is returned to the department within the time prescribed, the tax payable will be restricted to the amount due after deduction of the relief. Otherwise, the direct assessment will be made at twice the unit rate on the entire income as representing the normal liability, in which case, of course, the tax-payer concerned will be free to claim the relief within three years from the end of the year of assessment. In the case of those who are taxed at source, they must send in a written application for the relief, on receipt of which a copy of the form will be sent out to them. Ceylon income, non-Ceylon income and particulars of the claim for allowances, should be entered in this form. The relief is designed to substitute for tax at twice the unit rate on the Ceylon income the tax that would be payable by the individual on his total income from all sources if he were resident in Ceylon
and entitled to the various allowances, reduced in the
Ceylon income.
roportion T prop Total inceome
Examples:
(1) 4 is a Ceylon pensioner living in the United Kingdom. His pension is Rs. 12,ooo. His United Kingdom income from investments is (187. I o.o, i.e., Rs. 2,5oo. He is married and has two children.

( 59 )
The tax due as a non-resident is Rs. 12,ooo at I5%, i.e., Rs. 1,8oo.
The tax that would be due if he were a resident of Ceylon is
Ceylon Income ... 0 ... Rs. I2,ooooo Non-Ceylon Income ... ... , 2, SOO' OO
Total Income ... Rs. 14,5oo'oo
Earned Income Relief ... Rs. 2,4oo' oo Personal Allowance . . . . 2OOO “ OO Wife Allowance ... ... , I,OOO - OO Child Allowance ... ... , I, 5oo * oo , I, 6,9oo* oo
Taxable Income ... Rs. 7,6oooo
samaanseroasiasa
Тах: Rs. 6,ooo (д) 74% ... Rs. 45o-oo Rs. I,6oo (@) I 5% ... ,, 24o‘ oo
Rs. 69o • oo
The tax payable is
I2OOO
Rs. 69o X == R.s. 57I • oo
I 4,5 oo
The relief is
Rs. I,8oo—Rs. 57I = Rs. I,229ʻ oo
(2) B is a United Kingdom resident and has Ceylon dividends of Rs. 12,ooo; tax paid at source Rs. 1,440. His non-Ceylon income is
Trade (187. Io.o, i.e., Rs. 2,5 Oo.

Page 36
( 6o )
United Kingdom dividends, (375.o.o, i.e., Rs. Sooo. He is married and has two children.
The tax that would be payable if he were resident in Ceylon is
Ceylon Income ... 4 ... Rs. I2,ooo oo Non-Ceylon Income ... a . . . . 7, 5 OO" OO
Total Income ... Rs. I9,5OO‘ oo
Earned Income Relief ... Rs. Soo' oo Personal Allowance . . . . 2OOO “ OO Wife Allowance ... . . . . . IOOO" OO Child Allowance ... ... 2 I» OO'OO 22. OOO“ OO
Taxable Income ... Rs. I4,5oo oo
Tax: Rs. 6,Ooo G) 7% ... Rs. 45 o' oo Rs. 8,5 Oo (@) I 5% . . . ,, I,275 * OO
Rs. I,72 5 • oo
I2,OOO Rs. I,725 X -- = Rs. I,o62 • oo
Ι9, 5 οΟ
Tax paid at source a ... Rs. I,44o‘ oo Tax due ... A * * * ... », I, o62 * oo
Tax refundable ... Rs. 378 oo
If the tax-payer had been resident in the British Empire for only a part of the year of assessment, he would be entitled only to proportionate relief. It must be noted that this relief is not double tax relief but a special relief.

( 6 Ι )
107. As it is at present, British subjects resident in British India or Burma are entitled both to this relief and to the double tax relief under section 46 (see paragraphs 1o 3-1 o5). Where the two reliefs are claimed by any such individual, the relief under section 46 is limited to one-half of the Ceylon tax paid after deduction of the relief granted under section 45 (2), provided, of course, that this one-half does not exceed one-half of the corresponding tax paid in British India or Burma.

Page 37
CHAPTER XX
PAYMENT OF TAX
108. The tax charged by any assessment should be paid in the manner directed in the notice of assessment on or before the date or dates specified in such notice. As a rule tax is payable in two equal instalments. If the tax due on a specified date is not paid, the person by whom such tax is payable will be deemed to be a defaulter, and the Commissioner may order that a penalty not exceeding twenty per centum of the amount in default be added to the tax and recovered forthwith.
109. Individuals whose principal source of income is the profits of an employment are allowed to pay the tax due by them, as far as possible, in twelve equal instalments. Those who wish to avail themselves of this concession should make a written application not later than twenty-one days after the date of the notice of assessment requesting that the tax due by them be deducted from their salary.
110. The mere fact that an appeal has been lodged against an assessment does not entitle the person assessed
to withhold payment of the tax on the due date-see paragraph II 2. -
( 6.2 )

CHAPTER XXI
APPEALS
Appeal to the Commissioner
111. Any person aggrieved by the amount of an assessment may appeal to the Commissioner in writing stating precisely the grounds of his objection. This should be done within twenty-one days from the date of the notice of assessment. The Commissioner may, however, entertain a late appeal if he is satisfied that the delay in appealing was due to sickness, or absence from Ceylon, or other reasonable cause. If the assessment appealed against had been made in the absence of a return of income, the notice of objection would not be valid unless and until the return has been duly made.
112. On receipt of the notice of appeal, the Commissioner usually causes further inquiry to be made by the Assessor who made the assessment and informs the appellant that he has done so. At the same time he informs the appellant if the collection of the whole or any portion of the tax in dispute is not to be made. If the appellant is not told that any portion of the tax need not be paid pending the settlement of the appeal, he must pay the tax as directed
in the notice of assessment. Otherwise penalties would be added.
113. If the Assessor and the tax-payer have not come to an agreement, the Commissioner will hear the appeal ( 63 )

Page 38
( 64 )
at a fixed time and place. The tax-payer or his authorised representative should attend at the hearing. The Commissioner will record his determination in writing and announce it orally.
Appeal to the Board of Review
114. If the appellant or his authorised representative is dissatisfied with the determination by the Commissioner he should declare such dissatisfaction orally immediately after the announcement by the Commissioner of his determination or communicate it in writing to the Commissioner within one week from the date of such determination. The Commissioner will, within one month of the date of his determination, transmit in writing to the appellant or his representative his determination and the reasons therefor. Within one month of the transmission of such determination the appellant may give notice of appeal to the Board of Review. Such notice will not be entertained unless it is given in writing to the Clerk to the Board of Review and is accompanied by a copy of the Commissioner's determination, together with a statement of the grounds of appeal therefrom. Thereupon the Clerk to the Board fixes a time and place for the hearing of the appeal, and gives fourteen clear days' notice to the appellant and to the Commissioner.
Appeal to the Supreme Court
115. The decision of the Board is final; provided that either the appellant or the Commissioner may make

( 65 )
an application requiring the Board to state a case on a question of law for the opinion of the Supreme Court. Such application will not be entertained unless it is made in writing and delivered to the Clerk to the Board, together with a fee of fifty rupees within one month of the date of the Board's decision.
Appeal to the Privy Council
116. An appeal from the order of the Supreme Court may also be made to the Privy Council.

Page 39
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Page 40
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pələhuə əq pqnoqs əanneu ÁgælunĮoA e jo sɔɔueAoIIe sou peļņdeo Jo səssos oN.
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· Ił-61 ‘Io qɔɲɛIN L LLLL LLLLLLL LLL LLL LL LLLLL LLL LL LL LLLL L LLLLL 0LL LLLL LLL LLL SLLLL S00 LLLLL LLLL LLLLL LLL L LL LL LLL LL LLLLLL LLLL LLLLL LL L LLLL LLL LL SLL0L SLL LLLL LLLL LLL LLL LL LLLLL LLLL jo ugno, nɔɔɓoɔ puɛ ənji e ɔxseu on spāņnbəI Áqələų ɔsɛ noÁ ‘(881 'deo) ɔɔucuspio xe L ətuoɔuI əq Jo ɔnɑɑA Ág
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必鲁多鲁基必鲁s鲁弗里曼身必罗必弗必岁必也必必必象鲁安心举岁者必自单鲁鲁鲁兽男卷曾曾受自身多多岁多罗多岁者身心自尊心
奥鲁鲁鲁鲁鲁鲁角鼻多岁象鲁必争第必单也必曼多里鲁多由学易史学,受鱼雷曾多电影角兽弟弟弟必必曾曾曾受自身身也受专员色
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e as & & & & & & & & • • & * & * * * * * • • • • • • • • •名字身男象鼻安安 é必多名多蒙象各身鲁曼自鲁员鱼目多角鼻必须是必身史罗多身弟弟鱼必ss是自必备第食者身多参鲁者必备电
电影里必必必虫兽男必必学
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Jo : dyqsuəunued Jo quətuɔɔā3e ɔųą us pəueu qsag sį (o)
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Page 47
·ɔuroɔus əų. Jo uopɔnpoad əq, ug noÁ Áq pɔɲɔnɔus səsuədxə IIe ouņɔnpəp Jonge unq ÁueduIO3 3upsu.eq e os įsəgəgus ndɔɔxɔ īsəgənüỊ Áüe ĝuņồnpəp ynoqiț¢a pəlɛɲɔŋɔɔ ɔq ısňuu pəuunì3ị əuuõɔus 3ưI,
opəJedəId uəəq əAeų sunoɔɔɛ əų, əgep awqA og dn ɔyɛns o 1961 °1% qɔɔ ɛyʊ pəpuə JeəÁ əqą Joj shunoɔɔe uo pəseq qou sỊ əuoɔuỊ əq, JI ‘z
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· % 33ed go luonnoq əqą nɛ pəuuỊeso ssos əų puɛ pənəŋuɔ ɔq pqnoqs. GINON ,, oəpeu sea “ɔɲə səunųnɔɲ3e ossəugsnq oəpeIn uỊ pəJunɔu; ossos e əzəqA og
*usoj əųą os socq pəŋ ŋɛɔ spɛąo, əų, pue1၁၁qs əlɛJødəs e uo pələhuə əq pȚnoqs sisen op [[ng əų, o oeds Kue uỊ sŋɛɲəp [[nj əpnļous on tuoo) suɔsɔŋjnis jou sự ảJoq, jį oz
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‘AOIọq uəAį3 əq pinọqs Saesnɔŋŋed Ing ‘luotųÁoīduo ao fuoņeɔoa‘uosssəgozd ossəuỊsną open e aspiaxo so uo Áureo o, poseəo ao ospioxə að úo Krie, os pɔɔuəuñuñoo nok ooł61 orç qorėję sous jį
‘Aosəq uəAț8 ɔq Pinoqs steinɔŋɔed Ing ‘oyéi ‘Io qɔɲew əəuss sɔɔunted se pɔsɛɔɔ wo sɔɔuixed se pɔɔuəutuoɔ sɔɔunaed oq, yo kue3I
(orqpɔŋddo auoqat sørpo /so ug pəgəyɖuɖoɔ ɔq o L) ‘OJLOEI ‘SSGINISO 8I NI GIÐNVHOƆ
soous 31 eredəs e uo pələŋuɔ ɔq pinous sɔɔuersuunɔŋɔ ɔq, go ɔnou e poasoɔɔr əq you IIIA asəgənu! Áue neq, osoddņs ou woseə, əaeų noÁ JI opɔũsuoi oq isntu nou ao pț¢đ joqgoqa sɔnpIIəg qɔsɑɑ ɔsɔɔɔnus Jo aunotuɛ əq, pue ouəAį3 og Pinoqs Joaqəp əq. Jo ssəappe pue əueu əĝi asəgəsuį jo ɔsɛð öųí up
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Page 48
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Page 50
“CII 'ON tugog e Joy Adde pue sueIq \! unnas pīnoqs əų senpỊApus ue qɔns kq poaņoɔɔ si tugog sỊq. JI 'oooooo oss anoqe ueq, ssȘI sỊ sɔɔInộs IIe tuong ətuoɔus ssq ssioneįoqi ôn ởripiš! jaŋɔɔ jeŋɔɔdŞ oosduus qsņķig əų, ūs suəpssəā nɔɔsqns qsŋŋgɛ ɩdɔɔxə‘uosÁəõus quəpssər you fenpsapuỊ Ảué ou osqëössääėsự từïog sắt – g.NI ‘oquo soɔ oəɔŋJO xei, əuỊoouI
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NOTAZIO NI SGIOXIQOS TTV WOH + 3HWOONI

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・・・・・・、・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・・。。。。。。。。。。
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鲁曼多争鲁鲁鲁兽 萨曼第章m争事是普鲁---鲁多曾豪言 -鲁曼单
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• • • • • •#61* • • • • • • • • • • • • • • • • • • • • • • • • • • •
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oroP Ssq; uong sų, uoui oan usqțA ətu os pələAII2p əquŝnur qosqa ugog sțų uo orł61 orçqɔɲew pəpuə ɲɛɔÁ əq, Jogourosup 30 uomio, soodoo puɛ əna, e ossetu on pəIȚnbəI Áqələq əre nok (891 odeo) ɔɔutupio xerətuoɔus ɔq, yo ɔnusA Ág
zŷ-Is6I ouauussəssy yo reəx
XVI, BIJWOONI NOTĂŢIO
• • • • •****************念曾曾曾曾曾曾曾曾曾多多曾多多罗安日象鼻鱼ss影s às & & & & &加 。
YSYYSYSYYSSSSYSYYYSYSSSSSSSYYYYYYYYYYYYSYYYYS
·····························ør
(THIďWEI HSILIHA NI SLNĀCIISGYI)otgūnųɔ3 ssqa on ouņe[3] uoŋɛɔyunuuuuoɔ
Áue us 'oN ots& 3\otib ɔsɛɔsɑ oo/1(gn)-izEITI, 0 1 "ON W810)

otuopui sao L .V
·ɔuroɔus uosÁəo -: 'zỊA ‘iunotus 3ưȚAoIIo; ɔq ɔnp əsțAIəųo xei əų. Jog olnuņsqns on sy gɔŋɔ, 38 L (v postao 9q Áætli ssq L 'suɔpssəā uosÁəɔ ön päiữerằ səəueadose šnosuwa 3ų, či pəțiņuò puɛ üðtöo us suopssə, ələA tempsApus əq, JĮ sɔɔnos se ulog Əuloous teno, əų, uo ənp əq pȚnoa qosqa xei əų, ɔmɑnɔțep
-: Nouustu ŝuļAOIŢog əq us le pəAȚIIe s, jɔŋɔɔ ɔq L · §
*ooooooo oss inoqa ucq, ssəI si sɔɔanos IIe ulou; ɔuloous segon sțų jį ‘xei, ətuosus UoIÁɔɔ tuong gɔŋɔɔ usouso os pəņņuə sỊ ĐỊdura qssựg əųı üį suəpssɔ, sɔɔsqns qsḥg v šį oqa senpțâyptįυν ν
*ɔULỊCaesae; uosÁɔɔ teno, spq uo (suɔɔ ɲəd $1 go əlɛ, ɲɛgɛ ɲɛ fɔɔutasus ısıg əq. us osqeəầreqɔ sį uosÁɔɔ us luopţsər you uostod y ·
-'Aosəq o pue o sɔsou uỊ pɔqŋɔsɔp gəŋɔɔ ɔų upepo os qsỊA oqA oəņđugqsț¢sig əq us suɔpɔsɔɔ sɔɔə{qns qssaquq (q) pue ‘uosÁəO us wuɔpţsər suosiɔd (p)
—Áq pələIduloɔ ɔq pȚnoqs o puɛ ɛ sɔɓe) oz.
‘’sɔsɔɔ IIe uỊ pələĮduoɔ ɔq pqnoqs z əĝeq -1
səho N メroquiosoɔ ‘ɔɔŋJO xeĮ, əulosus

Page 53
‘ “ ’sYI [ego L, a
4240ạp popmfou, sou ostfolaq aoq; O ‘l
•**ța orţfamosus ‘spuəpțațCI ‘9
fruøys o 9
ɔɔuopprøys fo omfp/1 fontuus’ o
(ruotsuɔɖ Župmpus) osuotasoyqtaq '%
ruopose/omos pup orsøugong ‘reppu L oz.
2anţnoțužov · 1
*SYI -uoỊKəo uỊ səəunos uuox; əluoɔuI
·Âueduuoo ouȚĂueq e os qđɔɔxɔ opped asəgənuỊ Áue ouņɔnpəp qnoqasaa pəugnų33 34 msnuu ɔuoɔus IIV • 9
*'pɔJəguə əq pȚnoqs xe4 Jo uoŋɔnpəp omofoq sunoue sso:3 Əq, “oso ossəgəgus ‘spuəpỊAsp uIoI3 pɔgɔnpop uəəq seq xe L 9uuooUI Áuɛ ələų.A. ož SLLLLLSLyL SLLLLL LLLLL LL L LLLLL LLL LLLLL LL LLLLLL SLLL LLLL L LLLLL LL LLLLLL LLL LLL S
-‘uluoj əų, og sɔɛq pəļāJeo speso, əų, pue nɔɔqs əgeredəs e uo pələŋuɔ ɔq pinoqs sĻeņɔp sȚng əų, oɔɔeds Ấue uỊ sĻeņəp II ng Əprųɔus og uuoo; suəŋɔgns sou sį ɔxɔɖ? JI 'z
*ougOɔŋŋ. s.3g|A inoÁ sỊ \! \eq $uņɛɔspuỊ əpeu ɔsou e pue osɔɔɛds snoụeA əų uį pələŋuɔ ɔq pȚnoqs ɔJIA InoÁ Jo ɔtuoɔus ot{L ‘i
səŋoN [e]3ų39 [#6Ë ‘Io HOHVW CIGIGINGI YIVOTĀ ĢIHL HOH SHWOONI TWJLOJL HO LNHW GILWLS
( z )

o puse o sə8ed əgəIduloo oqaa suosiad Áq pənə[duoɔ ɔq you pəəu uoụeresoɔp sqq.L., AopỊA JO ‘pəŋuetu ‘JaysuȚds JaqəqA əgens ueuroA e JI-‘q’N
* & * *** y V*** ***** ***& & & * & * • • • • • • • • • • • • • • •****** : ovuəpprøys appataas
• • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • •;auntouățy
· · · · · ·#6; * · · · · · · · ·······················goKepo.............................sįq.pənɛCI
ogsaa Kuu puse JiasÁuu jo uosÁəƆ uỊ sɔɔrnos tuong əuoɔu, əų, jo əỊoqaa əųɔ pəsoțosip əAeq I neq; pue LLL LLL LL LLL LL LLL LL LLLLLL LLLLLLL LLL LL LLLLL LLL LLLLLLL LLL LL LLL LL LL LL LLLLLL LS
** -->osYI [ego L
otɔ sɔummymoquão osassəugomą orappuy ug pəuamoup rərroT · % səõunqo /vmuun məqạo luo opmuun “suau pumouso oz. | 掌nsəgənuIosYI
ssəappy s Joyspɔ sɔəuueN s Joyspɔ sɔÁısınɔəSJoqqəCIJO }ɔnɔɔs ɔ i sunouuy
supos ao səão3taoua uo frøuətus ‘ı
"SYIəuoɔuỊ Đaoqe əų, uoxy suoņɔnpəGI Joj suuseio攀

Page 54
*SYI [ego],
24ọqopopnjou! fou rrisoadsaño
oro ogromoțul “opuəpțațq
pup(I fo uospodnooo aqq tao.af orffoads
pupo I puɔ fɔrmoH fo omfp/1 ppmuus,
(ruotsuɔɑ Župmpus) fruøa (os quaeq
suoțofofou,I pup of roupong ‘roppa L
osYŁuosÁəo jo ano səɔɔnos tuo, ɔuuoɔus
(... ON,, Jo ... səX ,, ɔyɛ4S)***********************• • • • • • • • • • • • • • •č {{HIdWEI HSIJLIH9 EIHL NI LNĀCIISȚIH QOX ĦXIV (...ON��30めSƏĀ33ɔyɛ,S)• • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • •ċ„LOGIÍgnSHSI LIYH8||V[]OÅ{{HV
osoo2-Is6i ‘ī£ HOHVýN CIRCINH (HVHĀ ZIHL HOH SHWOONI TVLO L HO LNGIWGILVLS ( s )

osYI [eļOL
**ța oroscoutonq oppus ut pomanzug rørforȚ os
fø5.4pqɔ fɔnuup aoqto ao opnuup ‘quom punoaso oz
• • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • •
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• • • • • • • • • • • • • • •
• • • • • • • • • • • • • • •
‘SYI
ssɔɔppy sąogspɔgɔ
ɔugeN s, soņịpɔJOÁųānɔəS
asəgənuI ' ossi
Jo ɔɲɛYI
4qəP JO Junotuy
upor 40 oãoïquota uo soɔ məgus 'I
əugoɔuI əAoqɛ əų) ugong suoņɔnpəq zog suuỊeso
ら撃

Page 55
* 1961 o 1% qɔɔ ɛyʊ pəpuɔ wɛɔÁ ɔų, susunp pəȚIIeuun puse ouỊAų ɔɲəA uəapųųɔ ɔAoqɛ əq} \eq, əlɛsɔɔp I
$寸£z - .± & Ił-61 osv61o 1 % qɔɲɛJN1 #76Inuouqs, (qensə
* 1 Isady uo suvəÁ zz Jopun puel on JeəÁ uỊ | ‘1% qɔɲew o!Țeuoņɛɔnpə ut se uoŋɔn ŋsus əuuņ-IȚng sjæ3Á 91 13Ao pūsųɔ e jo əsɛɔ əqıþuəuuÁoīdu) | yeɔÁ UỊ pīļųɔq}3{{IŝuỊAsɔɔəI se^ oooo1 ‘I Įgdy uo sue3Á žz 1ɔpun us suɔuuqsỊqeqsg IeuoņɛɔnpoqJO əbensos | Jo əuIO3uIJo əlɛCI | puɛ ə3ɛ ɲɛq. 13AO JĮ ‘oqAA Jo ‘os:61 ‘I IŲdy uo əų. Jo ssəuppy puɛ əuueN s ossəussng ÂueĻeņOLsupos 81 àɔpun puɛ orłór o 1% qɔɲɛJN Oị loạK ɔų, pĮĮqɔ əų, peH3ussnp ouỊAȚI sɛA oqAA pņųɔ Áue jo səuuæN IIn I
· Ił761
‘1% qɔrɛyʊ pəpuə Jø3Á əųı 3usanp ȘuțAII əgəA oqAA (uəāpīļqɔ pəndope you inq ouəup!!!!3-dəıs ĝu!pnpu) NGIYICITIHO—og
*uugog sȚq, jo o pƯe z sə3 ed uo əuoɔus Jaq pəpnỊou, əAbų I seq. (3)
pue ‘uoŋwurdəs jo pəəp pɔɔnɔɔxɔ ÁȚnp. Jo sūnoɔ ŋuɔɲəduoɔ e go ɔəJɔɔpɛ ɲɔpun əuu uuoJJ JJede ouȚAȚI sou sæA əqsuvų (q)
*1*61 o 1% qɔɲew pəpuə JeəÁ əų, ouļīnp əg|A Kuu sesa pəlubu əAoqɛ əųn (ö)
—qeq, ɔJeỊ3ɔp I‘‘‘‘‘‘‘‘‘‘‘‘‘‘ : (ɔJỊA Jo səueu IIng) GIJIA—ov SĢION WAO”I’IW YŁOH SWEW TO
· 1 33ød uo o puɛ o səmou uį pəqỊJosəp JəŋɔJ əq, Uuqep ou qsỊA oqA əIȚduq qsņņg əq, u, quəpssəI sɔɔə{qns qsņțiq (q) puɛ ‘uosÁəO UỊ quəpssə, suosjod (p) Áq pələqduoɔ ɔq o, sį əĝɛd sțųL—’g’N
( o )
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AopỊA so ‘pəŋaeuu ‘sonsuỊds 19q1ɔqaa əgens uetuoA e Ji-oq'N
••••••••••••••••• • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • • •;ɔɔuoppføYI østatuas
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·······goKep... ··················sų,pəŋɛCI
‘uosÁəo jo uno sɔɔɔnos uogg $ 33ed tio (q) pue uosÁəO us sɔɔɔnos tuong z 33 ed uo (c) 2JA Áuu pue JosÁuu jo əuoɔus æq, jo ɔsoqa õųă pɔsopsp əAeų I seq, pue 3ɔɔɓoɔ Pue ɔnɔ, əue uango: spq us pəuțesuoɔ sɔuəuuəyens aq, IIe səŋɔq pue auəuusopns Kuu jo įsəq əų, og heų, əge[3ɔp I
NOLLWYBIVTOGICI
• 176 s “to qɔɲɛW pəPuə ɲɛɔÁ əq} \noq3nogų, əu Áqopəuseguļotu puɛ əuu qațA 3ưỊAII 273A səaņețoa ɔaoqe əq} \eq, og epop I
£양zI 1961 ‘Io qɔge W og JeəÁdịqsuoŋesƏYIɔuueN [[n:+ uỊ oaŋesƏYI jo ɔuoɔuI [ego L
noÁ qụA 3uȚAȚI ‘ɔg|A anoÁ Jo象 JIosunoÁ goo(g. qdex3eged Jepun ɔn.P. sį ɔɔuea.oIIe ou tuoqÅ žoj) pīļqɔ ao “uonsis ouɔqạouq oquored e og Ásuo Sosidde spqL
--SEHALLVIÐH LNGICINĦAGICI-‘O

Page 56

INDEX
Accounts s Agent, of non-resident business man ...
y 9 iss partner Agriculture, expenses as
s , general a s g , mature area, immature area, new clearing ... 99 , proceeds of sale of coupons... Allowance, child ... 0. 》》 , dependent relative as a s , personal 分》 , proportionate... , wife ...
99. , travelling ... as ao Annual value Annuity paid w a Appeal to the Board of Review ...
sy , Commissioner
s , Privy Council
s , Supreme Court ... Assessable income ... Assessments, estimated ... O 49 Authorized representative... Bad and doubtful debts ... Banker, interest paid to Basis of liability
Beneficiary X RKY ss , statutory income of ... Bonus
British subjects resident in British Empire
Business, accounts of
聊》 Child, allowance
, , definition of... Commission... Commuted pension, rate of tax on
Oompanies, mutual insurance , non-resident ... , resident o 0
ss
s
Contributions to pensions, savings, or provident funds...
, commencement or cessation of...
Contributions towards teachers' pensions ( 67 )
v.
Paragraphs
9 (α)
94
56, 6 Ι
16
I I
12-15
Ι7 54 (d)
και ο)
54 (b) 55 54 (ο) 24 40, 41 49 (b), 5ο II4 III-II 3 I I6
I I 5 49一宛2
5
6 45 (d) 45 (e) 2, 9 88, 89 87
22 Ιοβ 26, 27 9 (b), 9 (c) 54 (d) 54 (d) 22
79
77 76
75
97, 98, 99 43 (ዴ)

Page 57
( 68 )
Coupons, proceeds of sale of so Debts, bad and doubtful
Deductions, allowable
Deduction of tax at source... a on
by resident companies ... KO MA · · · from interest, rent, annuity, etc., to
s ss
99 ss non-residents
Dependent relative allowance Depreciation of plant, machinery, etc. Dividends, income arising from ...
, , paid by resident companies ... I R
, , , sterling companies paying Ceylon tax Dividends, refund of tax deducted from ... - - - 0. Double tax relief, Empire tax ...
39 s , United Kingdom tax ... Earned income relief as Empire tax, definition of ... su ow
s , double tax relief a (w Employment, commencement or cessation of ...
99 , profits from ... Executors o ow Exemptions ... Expenses, not allowable
,, . , travelling Ground rent paid ... Income, assessable ...
, , classification of ...
s , exempt from tax ... , , from partnership... , , statutory ... so
, taxable ... -- Income tax, charged in respect of...
sy year w
Interest, basis for returning
, , deduction from
, , in arrear е е , , irrecoverable o P.
paid
, received by money-lenders Leave pay ... 8 w Liability, basis of ... w qV g 8 so basis other than normal preceding year...
s disclosure of w is Ο Φ. Ο
of non-resident persons ... of resident individuals Loss in business a Machinery, depreciation of...
s , loss by selling ... 4 Net annual value o
Paragraphs
I7 45 (d) 45 8o-84 8o, 8.
82, 83
54 (e) (ه) 45 ,(a) 45
Іо4 πο3-Ιού, το 7 9 (ό), 9 (ο), το
8 49 (), So
9-12
7 57-62. 48 S3, S4
2 28 31 29
3o
و() 45 ,(a) 49
jo
32
2O
2.
9 3. 53, 9I-94 0»
4.
49 (e), 51. 45 (a), 45 (c) 45 (b) 40-43

( 69 )
Non-resident companies-rate of tax ...
s individuals, exemption of ... s s , rates of tax ...
9 persons, business on behalfo
s , past services in Ceylon of
yy , , services outside Ceylon of Partnership ... Payment of tax v « v Pension Funds Person, becoming resident.
, , ceasing to be resident ... Y 1- D , , death of a ... , , definition of Personal allowance ... Plant, depreciation of p
, , loss by selling Profession, accounts of O a , commencement or cessation of
a
«0 Q ib
Provident funds
Provident funds, withdrawals from
Rate of tax, Ceylon companies ... , , commuted pensions ... , , Hindu undivided family so , mutual insurance companies ...
Profits or income arising in or derived from Ceylon
so , non-resident companies 4 , , non-resident individuals . . . 4) es «
, , resident individuals
s , others ... O 6 KK QA * 8 4) + ab
Refund of tax deducted at source ... - Relief, British subjects resident in British Empire
, , earned income ...
from double tax ... e. 0. Renewal 0 0 1A− O KO ses Rent of lands and buildings 9 4 is on Rental value, definition of... a e , , , of free house... w Repairs, cost of a e Residence
Resident, absent from Ceylon for 12 months
, , if stay in Ceylon is for 6 months Resident individual, allowances due to w8 , , liability of ... 9s , , rates of tax ... Resident spouse, agent of non-resident spouse ...
, treated as non-resident Retirement from service ... O Separate assessment, both spouses resident 29 ss , husband and wife
罗钟 , notice of ...
ea ne
Paragraphs
76
93
74
94
92
9. 56-62 IO3- I IO
9 (e), пос
4 54 (β) 45 (a), 45 (6) 45 (b) 26 9 (β), 9 (ο)
97 23,97, 98 לך
79
76
77
76
74
72, 73
78
34-36 Ιο6, το 7 54 (α) поо-гоу, по7 45 (e) 39-44
Ιο, 20, 79 סך
66-7 Ι 66, 67

Page 58
( 7o )
Separate assessment, only one spouse resident ... wo Statutory income ... w w Sterling dividends, how assessed ... a 4 a *> , , received by non-resident individuals s so , set off of tax paid on... vo s Taxable income ... - Tax deducted at source, refund of... , set off of...
93 לל a Tax, payment of ... - O - - O Temporary residents O - Tenant, income of ... - - - w - O - is Trade, accounts of ... о о с a
, , commencement or cessation of ...
Travelling ... e a United Kingdom tax, double tax relief ... o ei s Wife allowance - - - - - - 4 x y w wo Wife, income of ... O Wife's income, tax due on ... 40 0 V s a
Paragraphs
7 Ι 48
37
38
37
S3, S4 34-36 34, 37, 84 Io8-IIo
96 و 95
4分
26, 27 9 (b), 9 (e) I8
IOO
54 (6) 4,66 68

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