Chapter VI A comprised sections 80A and 80D providing for certain specified deductions to be made in computing total income while section 85A, in so far as material, provides as follows: "85A. DEDUCTION OF TAX ON INTER CORPORATE DIVIDENDS: Where the total income of an assessee being a company includes any income by way of dividends received by it from an Indian company or a company which has made the prescribed arrangements for the declaration and payment of dividends (including dividends on preference shares) within India, the assessee shall be entitled to a deduction from the income tax with which it is chargeable on its total income for any assessment year of so much of the amount of income tax calculated at the average rate of income tax on the income so included (other than any such income on which no income tax is payable under the provisions of this Act) as exceeds an amount of twenty five per cent thereon;. " There were some amendments made in section 85A by Finance Act, 1966 but they are not material for our present purpose and we need not refer to them.