https://www.taxtmi.com/caselaws?id=169537 A dividend received by a company trading in stocks and shares was treated as a commercial receipt and included in trading profits assessable under Case I of Schedule D, even though it was paid out of untaxed capital profits and no tax was deducted at source. Section 184 of the Income Tax Act, 1952 was treated as a source-deduction provision, not a general exemption. The word "discovers" in section 41(1) was also held to cover not only newly found facts but later recognition that an assessment was undercharged because of an earlier mistake of law. On that basis, the additional assessment was valid. en-us Thu, 01 Mar 1962 00:00:00 +0530 Sat, 25 Apr 2015 11:26:49 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=169537 A dividend received by a company trading in stocks and shares was treated as a commercial receipt and included in trading profits assessable under Case I of Schedule D, even though it was paid out of untaxed capital profits and no tax was deducted at source. Section 184 of the Income Tax Act, 1952 was treated as a source-deduction provision, not a general exemption. The word "discovers" in section 41(1) was also held to cover not only newly found facts but later recognition that an assessment was undercharged because of an earlier mistake of law. On that basis, the additional assessment was valid. Case-Laws Income Tax Thu, 01 Mar 1962 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=169537