Judgement FACTS :- The question referred to the High Court by the Tribunal was as follows : "Whether on the facts of the case, by reason of the provisions of S. 5, Excess Profits Tax Act, the excess profits tax officer was justified in changing the method of computation of the assessee firms income for excess profits tax purpose, disregarding the method of accounting regularly adopted by the assesses firm under Ss. 10 and 13, Income-tax Act, and accepted for income-tax purposes ?" CHAGLA, C.J. :- The assessee is a firm of guarantee brokers of the Aruna and Saraspur Mills at Ahmedabad. They received brokerage at half per cent. on all sales made by the mills. The assessees maintain their accounts on cash basis and they credit in their books of account the amounts actually received by them from the mills in respect of their brokerage, and these entries are made when the brokerage is actually paid. For the purposes of income-tax this mode of accounting was accepted by the Department and it is not suggested that this mode of accounting is in any way incorrect or does not enable the Department to truly assess the profits of the assessees. But the contention put forward by the Department and which was accepted by the Tribunal was that whatever might be the position under the Indian Income-tax Act, under the Excess Profits Tax Act the assessees cannot maintain their accounts on the cash basis for accounting and they must make their returns for the Excess Profits Tax Act only on the mercantile basis. In other words according to the Tribunal the assessees must enter in their books of account brokerage when it accrued due to the assessees and not when it was received by them. The question is whether this view of the Tribunal is justified by the provisions of the Excess Profits Tax Act. 2. The Tribunal has relied on S. 6 for coming to the conclusion that it did and that section as the marginal note correctly indicates deals with the application of the Act to the particular businesses mentioned in that section. That section provides that the Act shall apply to every business of which any part of the profits made during the chargeable accounting period is chargeable to income-tax by virtue of the provisions of sub-cl. (i) or sub-cl. (ii) of cl. That section provides that the Act shall apply to every business of which any part of the profits made during the chargeable accounting period is chargeable to income-tax by virtue of the provisions of sub-cl. (i) or sub-cl. (ii) of cl. (b) of sub-s. (1) of R. 4, Income-tax Act, 1922, or of cl. (c) of that sub-section, Now, when we turn to S. 4(1)(b)(i) and (ii) we find that they deal with accrual of income in or without British India and sub-cl. (c) also deals with accrual of income in British India of a person not resident in British India. Section 5, Excess Profits Tax Act, does not refer to the income which is received in British India under S. 4(1)(a). From this fact the Tribunal has drawn the inference that charge of excess profits tax is only to be made on income which arises or accrues to the assessee and not which is "received" by the assesses In other words the Tribunal has looked upon S. 5, Excess Profits Tax Act, as the charging section and not as a section which deals with the applicability of the Act. With respect that is a fallacious reasoning which has led the Tribunal to the conclusion that the assessees are not entitled to maintain their accounts on the cash basis. The charging section is not S. 5, but S. 4, and when we turn to the other provisions of the Act it is clear that the right which the assessees have under R. 13, Income-tax Act, of having their income, profits or gains computed in accordance with the method of accounting regularly employed by them has not been taken away by the Excess Profits Tax Act. In the first place we have S. 21 of the Act which expressly incorporates in the Excess Profits Tax Act the provisions of S. 13, Income-tax Act, and therefore whatever rights the assessees have under S. 13, Income-tax Act, are maintained in the interests of the assessees in the Excess Profits Tax Act. Then when we turn to Sch. I, which is the schedule according to which profits are to be assessed, R. 1 itself says that the profits of a business shall be computed on the principles on which the profits of the business are computed for the purposes of income-tax under S. 10, Income-tax Act. Then when we turn to Sch. I, which is the schedule according to which profits are to be assessed, R. 1 itself says that the profits of a business shall be computed on the principles on which the profits of the business are computed for the purposes of income-tax under S. 10, Income-tax Act. Now, the effect of the decisions of the Tribunal is that S. 5, Excess Profits Tax Act overrides S. 21 of the Act and R. 1 of Sch. I. But the proper method of construing a statute which has different provisions is not to come to a conclusion that one part overrides another part of that statute but to try and see whether different parts of the statute can be reconciled so as to present one complete picture. But in this case it is not necessary for us to reconcile different parts of the Excess Profits Tax Act at all. If S. 5, Excess Profits Tax Act, is not the charging section then under S. 21, and under R. 1 of Sch. I, it is clear that the principles contained in S. 13, Income-tax Act, are made applicable to the Excess Profits Tax Act as well. Therefore if the ordinary mode of accounting of the assesses was cash basis, then there is no reason why they should not be allowed to use the same mode for making their returns for the purposes of the Excess Profits Tax Act, and the Department is bound to assess the assessees to excess profits tax on the cash basis and not on the mercantile basis. The result is that we must answer the question submitted to us in the negative. The Commissioner to pay the costs of the reference. Order accordingly.