https://www.taxtmi.com/caselaws?id=170646 A liquidation distribution treated as a deemed dividend under section 2(6A)(c) of the Indian Income-tax Act, 1922 could not be taxed under section 44-F. The Court held that section 44-F applies only to income from shares or securities arising in periodical form and capable of being apportioned over time, whereas a liquidation receipt is a distribution of company assets and not income generated by the shares after liquidation. The deemed-dividend fiction in section 2(6A)(c) was confined to its own statutory purpose and could not be extended to section 44-F. The taxing provision could not be enlarged by implication, so the assessee succeeded. en-us Tue, 29 Aug 1972 00:00:00 +0530 Fri, 07 Apr 2017 11:17:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=170646 A liquidation distribution treated as a deemed dividend under section 2(6A)(c) of the Indian Income-tax Act, 1922 could not be taxed under section 44-F. The Court held that section 44-F applies only to income from shares or securities arising in periodical form and capable of being apportioned over time, whereas a liquidation receipt is a distribution of company assets and not income generated by the shares after liquidation. The deemed-dividend fiction in section 2(6A)(c) was confined to its own statutory purpose and could not be extended to section 44-F. The taxing provision could not be enlarged by implication, so the assessee succeeded. Case-Laws Income Tax Tue, 29 Aug 1972 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=170646