https://www.taxtmi.com/caselaws?id=6478 Commercial profits credited to a tea company's profit and loss account and general reserves remained accumulated profits for dividend on liquidation, even though part of the underlying income was treated as agricultural income under the tea apportionment rule. The 60:40 split governed assessment of tea income, but it did not require a further division of commercial reserves once credited in the accounts. By contrast, surplus arising from sale of tea estate land and related revaluation reserves were not generally includible as accumulated profits because land yielding agricultural income was outside capital gains, except to the limited extent actually brought to tax as capital gains. en-us Mon, 26 Apr 1976 00:00:00 +0530 Fri, 05 Dec 2008 00:00:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=6478 Commercial profits credited to a tea company's profit and loss account and general reserves remained accumulated profits for dividend on liquidation, even though part of the underlying income was treated as agricultural income under the tea apportionment rule. The 60:40 split governed assessment of tea income, but it did not require a further division of commercial reserves once credited in the accounts. By contrast, surplus arising from sale of tea estate land and related revaluation reserves were not generally includible as accumulated profits because land yielding agricultural income was outside capital gains, except to the limited extent actually brought to tax as capital gains. Case-Laws Income Tax Mon, 26 Apr 1976 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=6478