https://www.taxtmi.com/caselaws?id=175462 A distribution by a liquidator from the excess realised over the written down value of capital assets was treated as a capital return, not real profit, and the legal fiction in the second proviso to section 10(2)(vii) was confined to taxing that excess in computing business income. That deemed profit could not be carried into section 2(6A)(c), because the phrase "accumulated profits" could not be expanded by implication in a taxing statute. The amount therefore did not fall within the statutory definition of dividend. en-us Thu, 22 Oct 1964 00:00:00 +0530 Mon, 23 Nov 2015 11:09:28 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=175462 A distribution by a liquidator from the excess realised over the written down value of capital assets was treated as a capital return, not real profit, and the legal fiction in the second proviso to section 10(2)(vii) was confined to taxing that excess in computing business income. That deemed profit could not be carried into section 2(6A)(c), because the phrase "accumulated profits" could not be expanded by implication in a taxing statute. The amount therefore did not fall within the statutory definition of dividend. Case-Laws Income Tax Thu, 22 Oct 1964 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=175462