https://www.taxtmi.com/caselaws?id=7208 Deemed dividend under section 23A of the Indian Income-tax Act, 1922 is treated by legal fiction as distributed to shareholders on the relevant meeting date, but only to the extent the statute permits. Where the company had become a foreign company and the deemed distribution was to be regarded as having occurred outside the taxable territories to a non-resident shareholder, Explanation 3 to section 4(1) did not apply because it concerned dividend paid by an Indian company outside the taxable territories. On that footing, the other definitions invoked did not extend the charge, and the deemed dividend was not taxable in the shareholder's hands. en-us Tue, 04 Jul 1967 00:00:00 +0530 Thu, 12 Feb 2009 16:48:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=7208 Deemed dividend under section 23A of the Indian Income-tax Act, 1922 is treated by legal fiction as distributed to shareholders on the relevant meeting date, but only to the extent the statute permits. Where the company had become a foreign company and the deemed distribution was to be regarded as having occurred outside the taxable territories to a non-resident shareholder, Explanation 3 to section 4(1) did not apply because it concerned dividend paid by an Indian company outside the taxable territories. On that footing, the other definitions invoked did not extend the charge, and the deemed dividend was not taxable in the shareholder's hands. Case-Laws Income Tax Tue, 04 Jul 1967 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=7208