https://www.taxtmi.com/caselaws?id=168789 In liquidation, the statutory definition of dividend applied only to accumulated profits within the six preceding years; current profits of the broken period up to liquidation were not treated as accumulated profits and could not be brought within the deeming provision. The amount assessed under section 23A in an earlier year was merely notional and never actually available with the company or liquidator, so it also could not form part of accumulated profits available for distribution as dividend. On both questions, the tax treatment favoured the assessee and the reference was answered against the Revenue. en-us Fri, 24 Aug 1956 00:00:00 +0530 Thu, 26 Mar 2015 16:24:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=168789 In liquidation, the statutory definition of dividend applied only to accumulated profits within the six preceding years; current profits of the broken period up to liquidation were not treated as accumulated profits and could not be brought within the deeming provision. The amount assessed under section 23A in an earlier year was merely notional and never actually available with the company or liquidator, so it also could not form part of accumulated profits available for distribution as dividend. On both questions, the tax treatment favoured the assessee and the reference was answered against the Revenue. Case-Laws Income Tax Fri, 24 Aug 1956 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=168789