| (a) | - | is specified to be free of income-tax and no deduction is made therefrom on account of the income-tax payable by the company, or |
| (b) | - | was being paid before the 1st April, 1960, without any deduction therefrom on account of the income-tax payable by the company, notwithstanding the absence of any specification that the dividend would be free of income-tax, |