https://www.taxtmi.com/caselaws?id=61757 For section 2(6A)(e) of the Indian Income-tax Act, 1922, a loan or advance to a shareholder is deemed dividend when made, to the extent of accumulated profits then available. Earlier advances that satisfied the deeming provision must be notionally deducted from accumulated profits even if they were not actually assessed as dividend in those years. Otherwise, accumulated profits would be overstated and the statutory fiction defeated. The later advance could therefore be taxed only to the extent of the remaining accumulated profits, and the assessee's contention succeeded. en-us Fri, 17 Aug 1984 00:00:00 +0530 Sun, 06 Feb 2011 03:04:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=61757 For section 2(6A)(e) of the Indian Income-tax Act, 1922, a loan or advance to a shareholder is deemed dividend when made, to the extent of accumulated profits then available. Earlier advances that satisfied the deeming provision must be notionally deducted from accumulated profits even if they were not actually assessed as dividend in those years. Otherwise, accumulated profits would be overstated and the statutory fiction defeated. The later advance could therefore be taxed only to the extent of the remaining accumulated profits, and the assessee's contention succeeded. Case-Laws Income Tax Fri, 17 Aug 1984 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=61757