https://www.taxtmi.com/caselaws?id=188911 Section 2(6A)(d) of the Indian Income-tax Act was treated as a valid deeming provision because Entry 54 of List I was construed broadly to include ancillary measures preventing tax evasion; it did not tax capital as such, but brought within dividend treatment only the accumulated profits element on reduction of capital. The provision was therefore upheld. On timing, "distribution" was held to require actual disbursement or crediting in fact, not merely a resolution, registration, or book entry; accordingly, the accumulated profits were deemed distributed in assessment year 1956-57, not 1955-56, and the Revenue succeeded on both issues. en-us Wed, 21 Feb 1962 00:00:00 +0530 Tue, 20 Dec 2016 16:47:13 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=188911 Section 2(6A)(d) of the Indian Income-tax Act was treated as a valid deeming provision because Entry 54 of List I was construed broadly to include ancillary measures preventing tax evasion; it did not tax capital as such, but brought within dividend treatment only the accumulated profits element on reduction of capital. The provision was therefore upheld. On timing, "distribution" was held to require actual disbursement or crediting in fact, not merely a resolution, registration, or book entry; accordingly, the accumulated profits were deemed distributed in assessment year 1956-57, not 1955-56, and the Revenue succeeded on both issues. Case-Laws Income Tax Wed, 21 Feb 1962 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=188911