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    <title>1967 (2) TMI 2 - CALCUTTA High Court</title>
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    <description>In proceedings on deemed dividend under the Income-tax Act, 1922, the statutory minimum had to be tested by reference to assessable income reduced by tax, not commercial profits. Commercial profits became relevant only at the later stage when the authority considered whether a larger distribution was unreasonable having regard to earlier losses or the smallness of profits. The Tribunal was wrong to mix these distinct inquiries while computing the dividend percentage. The order was not vitiated merely because no notice under the second proviso had been issued, and the assessee&#039;s challenge failed.</description>
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    <pubDate>Mon, 20 Feb 1967 00:00:00 +0530</pubDate>
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      <title>1967 (2) TMI 2 - CALCUTTA High Court</title>
      <link>https://www.taxtmi.com/caselaws?id=6800</link>
      <description>In proceedings on deemed dividend under the Income-tax Act, 1922, the statutory minimum had to be tested by reference to assessable income reduced by tax, not commercial profits. Commercial profits became relevant only at the later stage when the authority considered whether a larger distribution was unreasonable having regard to earlier losses or the smallness of profits. The Tribunal was wrong to mix these distinct inquiries while computing the dividend percentage. The order was not vitiated merely because no notice under the second proviso had been issued, and the assessee&#039;s challenge failed.</description>
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      <pubDate>Mon, 20 Feb 1967 00:00:00 +0530</pubDate>
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