Dividend received in the relevant year stayed taxable despite a later refund resolution, as later events could not alter completed assessment.

Dividend credited and received during the relevant accounting year remained taxable as income for that assessment year, because taxability is determined on the facts existing in the completed year. A later resolution requiring refund of the dividend could not change the character of the receipt or reopen the assessment position for that year. The assessment was treated as self-contained, and a subsequent event was held incapable of displacing income that was rightly assessed when received. The assessee's contention for exclusion was therefore rejected.

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Issues: Whether dividend received by the assessee in the relevant assessment year remained taxable as income notwithstanding a later resolution requiring refund of the dividend.

Analysis: The dividend was credited and received during the relevant accounting year and, on the facts then existing, was properly treated as income for that assessment year. The later resolution and any consequent liability to refund arose after the close of that year and could not alter the character of the receipt for the completed assessment. An assessment is to be treated as self-contained, and a subsequent event cannot be used to displace income which was rightly assessed on the facts existing in the relevant year.

Conclusion: The dividend remained taxable as the assessee's income for the assessment year in question, and the contention for exclusion was rejected.

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