https://www.taxtmi.com/caselaws?id=8053 For section 23A of the Indian Income-tax Act, 1922, only the commercial profits of the relevant accounting year could be taken into account when determining distributable surplus. Refundable excess profits tax deposits retained with the revenue were treated as refundable deposits made over several years, not as part of the year's commercial profits, and therefore were excluded from the profit computation. A proposed set-off against later tax liability was also rejected because it had not been raised before the Tribunal and, in any event, the deposit was not distributable commercial profit. The order under section 23A was thus upheld. en-us Fri, 20 Mar 1970 00:00:00 +0530 Fri, 27 Mar 2009 17:26:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=8053 For section 23A of the Indian Income-tax Act, 1922, only the commercial profits of the relevant accounting year could be taken into account when determining distributable surplus. Refundable excess profits tax deposits retained with the revenue were treated as refundable deposits made over several years, not as part of the year's commercial profits, and therefore were excluded from the profit computation. A proposed set-off against later tax liability was also rejected because it had not been raised before the Tribunal and, in any event, the deposit was not distributable commercial profit. The order under section 23A was thus upheld. Case-Laws Income Tax Fri, 20 Mar 1970 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=8053