https://www.taxtmi.com/caselaws?id=6348 Section 44F of the Indian Income-tax Act, 1922 did not apply to amounts distributed on liquidation as deemed dividend under section 2(6A)(c). The provision was directed at securities yielding periodical income that could be apportioned as accruing from day to day, whereas liquidation distributions represent a shareholder's share of the company's assets after the shares have ceased to be income-yielding. The deemed-dividend fiction in section 2(6A)(c) was confined to its own context and could not be extended into section 44F. As a taxing provision, section 44F had to be construed strictly, and its language did not clearly cover liquidation proceeds. en-us Tue, 29 Aug 1972 00:00:00 +0530 Mon, 19 Jan 2026 15:49:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=6348 Section 44F of the Indian Income-tax Act, 1922 did not apply to amounts distributed on liquidation as deemed dividend under section 2(6A)(c). The provision was directed at securities yielding periodical income that could be apportioned as accruing from day to day, whereas liquidation distributions represent a shareholder's share of the company's assets after the shares have ceased to be income-yielding. The deemed-dividend fiction in section 2(6A)(c) was confined to its own context and could not be extended into section 44F. As a taxing provision, section 44F had to be construed strictly, and its language did not clearly cover liquidation proceeds. Case-Laws Income Tax Tue, 29 Aug 1972 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=6348