In the case of a company whose business consists wholly or mainly in the dealing in or holding of investments and at the rate of thirtyseven percent, in the case of any other company on the undistributed balance of the total income of the previous year, that is to say, on the total income as reduced by the amounts, if any referred to in clause (a), clause (b) or clause (c) and the dividends actually distributed, if any. ." Explanation 2, to that section says: "For the purposes of this section, statutory percentage means: (i) in the case of a company whose business consists wholly or mainly in the dealing in or holding of investments 100 % . " We have now to see what exactly is the meaning of the expression "in the case of a company whose business "consists wholly or mainly in the dealing in or holding of investments" in the main section 23A and the expression "in the case of a company whose business consists wholly or mainly in the dealing in or holding of investments" in cl.