On the surface, it appears inexplicable: General Electric, a company that used the 1981 corporate tax leasing provisions to get a net refund of $100 million from Uncle Sam last year, is circulating a memorandum on Capitol Hill calling for restriction or outright repeal of those same provisions.

After describing the restrictions, the GE memo notes that "if the political climate is such that Congress finds these proposed modifications inappropriate or impractical, we would suggest full repeal of the safe-harbor leasing provisions."

In fact, however, either the restrictions or repeal would, if adopted, function to restore the traditional, old-style leasing market. And a significant portion of that market would be, according to experts in the field, controlled by General Electric Credit Corp. With the end of tax benefit leasing, the old leasing market would grow by leaps and bounds. With or without tax benefit leasing, GE makes out.

More important, if Congress vents its political embarrassment over the tax breaks given business last year by a highly publicized repeal of corporate tax leasing, it could function to reduce the drive to enact a significantly broadened corporate minimum tax, a levy considered anathema to GE.

In the same memorandum, GE contends the corporate minimum tax is "inherently inequitable . . . a counterproductive provision . . . and a ready-made vehicle for future corporate tax increases."

GE's posture--a willingness to jettison, with little economic pain, the leasing provisions while focusing on the minimum tax--has, however, provoked bitter anger among other business lobbyists, particularly those with strong ties to leasing, who have dubbed the firm "Greed Electric."

Frank Borman, president of Eastern Airlines, a leading advocate of tax leasing who has conducted a number of deals with General Electric Credit Corp., is furious with GE's lobbying tactics, according to a number of sources, although a spokesman for Borman downplayed any disagreement.

Such a split, however, would be characteristic of the growing division within the once-united business community as both Congress and the administration explore new vehicles to raise revenues to close the budget deficit.

Making matters significantly worse for the business community is the increasing concern among Republicans that the public perceives the party and President Reagan as anti-poor and excessively favorable to the wealthy and to corporations.

"There are a lot of people out there who firmly believe Republicans are a sort of heartless group," Sen. Robert Dole (R-Kan.), chairman of the Senate Finance Committee and initiator of both the corporate minimum tax and repeal of leasing, said recently.

The division is most apparent within an ad hoc alliance of business lobbyists known as the Carlton group. From 1978 through 1981, members of this coalition joined forces behind the business tax cut known as 10-5-3 and won a partially amended version of the measure. One faction--representing the beleaguered steel, automobile, airlines industries and others--also persuaded the administration to create the tax "leasing" program at a cost of $27 billion through 1986.

Unlike prior years, when the corporate community has divided between small and big business, service industry and capital intensive firms and energy consumers and energy producers, the first year of the Reagan administration created a brief political climate in which just about every interest could pick up a piece of the tax cut, although there remains some doubt about how well small business made out in the process.

Now, however, that unity has disappeared. Just to take a few of the participants in the Carlton group--which got its name because it meets Tuesday mornings for breakfast at the Sheraton Carlton--there are the following divisions: Two of the participants--the National Federation of Independent Business, which represents small business, and the American Business Conference, which is composed of growing, mid-sized corporations--are now adamantly opposed to tax leasing.

John M. Albertine, president of the American Business Conference, said his group is against tax leasing, but he readily acknowledged that the stance reflects self-interest: "our principal concern is the rate of accumulation of capital, and we want to allow resources to move from decining to expanding sectors. Leasing does just the opposite."

On the other side of the coin, Charls E. Walker, one of the city's best-known lobbyists and the "father" of the Carlton group, has organized a pro-leasing coalition of corporations that has little or no taxable income and wants to sell off its credits and depreciation through "leases."

Walker has the support of the National Association of Manufacturers and the U.S. Chamber of Commerce. But the Business Roundtable, which represents 200 of the largest companies in the nation, is lukewarm at best toward tax leasing and many of its members consider the publicity surrounding corporate tax sales to have been a major liability to the entire business community.

It is a reflection of the complexity of the tax fight that, while the chamber officially supports corporate tax leasing, its chairman is highly critical. "I think it is a lousy piece of legislation," Donald Kendall, who is also chairman of Pepsico Inc., said at a February meeting with editors. The legislation "in many cases only subsidizes bad management," he contended. Since then, Kendall has become more sympathetic to leasing, according to a chamber official, although the Pepsico chairman could not be reached for comment.

The corporate minimum tax, which is backed by the administration and by Dole, has picked up the opposition of most, but by no means all, of the business community.

The NFIB, calculating that the $50,000 exemption will protect almost all of its membership, has purposely taken no position on the minimum tax, while endorsing the general drive to reduce the budget deficit. In political terms, this translates into what might be considered a back-door endorsement.

In addition, calculations by the Treasury show that some industries have far more interest in fighting the minimum tax than others:

The industry that would be hardest hit is banking, which would see its federal tax liability grow from just under $890 million in 1982 to $1.89 billion in 1983, an increase of 112 percent. This would result because the minimum tax would fall on banks that now use certain provisions allowing deductions for the cost of loans to buy tax-free bonds to reduce their tax to little or nothing.

Similarly, the petroleum and refining industry, which would be penalized for using certain tax preferences in the law, would see its estimated 1982 corporate tax of $1.64 billion shoot up to $3.07 billion in 1983, an 87 percent increase. Utilities would go from $940 million in 1982 to $1.5 billion in 1983, a 60 percent hike.

Others, like manufacturing, would see federal liabilities increase, but, in percentage terms, by far smaller amounts. Total taxes on manufacturing would grow from $23 billion to $31 billion, an increase of 34 percent, and steel manufacturers contend they will have to absorb a disproportionate percentage of the increase in this category, making the increase smaller for other manufacturers.

Because of the sharp increase in petroleum industry liabilities under the minimum tax, the Independent Petroleum Association is fighting the proposal tooth and nail.

In terms of self interest, the group considers tax leasing "not much of an item," but, in the politics of rising taxes, Harold B. Scoggins Jr., vice president, noted tax leasing "caused us problems . . . to the extent that it has caused persons to look for other sources of revenue." The adverse publicity, he added, "has just fed the normal animosity people have toward the business community."

It is, in fact, the divisions within the business community that have made it far more vulnerable to a tax hike this year, although the pressure to close the deficit gap would, under any circumstances, lead many politicians to look toward business as a source of revenue.

The business splits not only cut across such broad tax questions as the corporate minimum tax and tax leasing--both big ticket items with annual revenue loss or gain of $4 billion or more--but also to far smaller questions.

Proposals to reform the industrial revenue bond program, for example, have created significant splits among the beneficiaries who, in the past, presented a united front. Industrial users of the tax-free bond issues are, according to congressional sources, arguing that commercial beneficiaries, like fast-food chains, should be eliminated. Nonprofit hospitals and universities are arguing that both industrial and commercial beneficiaries might be cut out. The commercial users, politically considered the most vulnerable, are conducting a rearguard attempt to preserve the entire program, according to Capitol Hill aides.