<?xml version="1.0" encoding="UTF-8"?>
<?xml-stylesheet type="text/xsl" href="https://www.taxtmi.com/rss_sitemap/rss_feed_blog.xsl?v=1750492856"?>
<rss version="2.0" xmlns:atom="http://www.w3.org/2005/Atom">
  <channel>
    <title>1968 (1) TMI 5 - GUJARAT High Court</title>
    <link>https://www.taxtmi.com/caselaws?id=7120</link>
    <description>Section 44F of the Income-tax Act, 1922 was construed as an anti-avoidance provision aimed at deliberate transactions entered into to reduce tax on income from securities, so it did not cover bona fide dealings or incidental tax reduction. The term &quot;income from securities&quot; was held to mean periodic yield such as interest or ordinary dividend, and it did not extend to a statutory fictional dividend arising on liquidation under section 2(6A)(c), which was treated as capital in substance. The proviso to section 44F(3) required both an exceptional, non-systematic instance and no similar avoidance in the preceding three years; it failed where prior avoidance had occurred.</description>
    <language>en-us</language>
    <pubDate>Mon, 15 Jan 1968 00:00:00 +0530</pubDate>
    <lastBuildDate>Tue, 10 Feb 2009 19:17:00 +0530</lastBuildDate>
    <generator>TaxTMI RSS Generator</generator>
    <atom:link href="https://www.taxtmi.com/rss_feed_blog?id=46175" rel="self" type="application/rss+xml"/>
    <item>
      <title>1968 (1) TMI 5 - GUJARAT High Court</title>
      <link>https://www.taxtmi.com/caselaws?id=7120</link>
      <description>Section 44F of the Income-tax Act, 1922 was construed as an anti-avoidance provision aimed at deliberate transactions entered into to reduce tax on income from securities, so it did not cover bona fide dealings or incidental tax reduction. The term &quot;income from securities&quot; was held to mean periodic yield such as interest or ordinary dividend, and it did not extend to a statutory fictional dividend arising on liquidation under section 2(6A)(c), which was treated as capital in substance. The proviso to section 44F(3) required both an exceptional, non-systematic instance and no similar avoidance in the preceding three years; it failed where prior avoidance had occurred.</description>
      <category>Case-Laws</category>
      <law>Income Tax</law>
      <pubDate>Mon, 15 Jan 1968 00:00:00 +0530</pubDate>
      <guid isPermaLink="true">https://www.taxtmi.com/caselaws?id=7120</guid>
    </item>
  </channel>
</rss>