https://www.taxtmi.com/caselaws?id=7693 Section 23A levy of additional super-tax could not be sustained on a profit-based approach alone, because the reasonableness of dividend distribution must be judged on commercial principles from the standpoint of a prudent businessman. The enquiry must consider the company's surplus funds, future requirements, reserves, past losses and other relevant business circumstances, since declaration of dividend is ordinarily a matter of internal management. The Tribunal erred in treating the existence of profits as sufficient by itself and in disregarding these commercial factors, so the levy was not upheld and the issue was answered in favour of the assessee. en-us Tue, 04 Nov 1969 00:00:00 +0530 Tue, 17 Mar 2009 16:05:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=7693 Section 23A levy of additional super-tax could not be sustained on a profit-based approach alone, because the reasonableness of dividend distribution must be judged on commercial principles from the standpoint of a prudent businessman. The enquiry must consider the company's surplus funds, future requirements, reserves, past losses and other relevant business circumstances, since declaration of dividend is ordinarily a matter of internal management. The Tribunal erred in treating the existence of profits as sufficient by itself and in disregarding these commercial factors, so the levy was not upheld and the issue was answered in favour of the assessee. Case-Laws Income Tax Tue, 04 Nov 1969 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=7693