https://www.taxtmi.com/caselaws?id=191535 Liquidation distributions were treated as dividend only to the extent attributable to accumulated profits immediately before liquidation, with the word "immediately" extending the charge to profits standing to the company's credit up to the liquidation date. The statutory explanation excluded only capital gains expressly carved out, so other capital gains remained within accumulated profits. However, proceeds from the sale of land yielding agricultural income could not be treated as capital gains under section 12B, and the assessing authority had to apportion composite sale proceeds between taxable and non-taxable components before raising a demand. The demand as framed was therefore not in accordance with law. en-us Thu, 03 Oct 1963 00:00:00 +0530 Thu, 06 Apr 2017 16:18:22 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=191535 Liquidation distributions were treated as dividend only to the extent attributable to accumulated profits immediately before liquidation, with the word "immediately" extending the charge to profits standing to the company's credit up to the liquidation date. The statutory explanation excluded only capital gains expressly carved out, so other capital gains remained within accumulated profits. However, proceeds from the sale of land yielding agricultural income could not be treated as capital gains under section 12B, and the assessing authority had to apportion composite sale proceeds between taxable and non-taxable components before raising a demand. The demand as framed was therefore not in accordance with law. Case-Laws Income Tax Thu, 03 Oct 1963 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=191535