https://www.taxtmi.com/caselaws?id=8425 For section 2(6A)(e) of the Indian Income-tax Act, 1922, accumulated profits mean profits brought forward from prior periods and available for distribution, not profits arising during the current accounting year. The provision for taxation and any declared dividend must be deducted when computing accumulated profits because they reduce the amount actually available for loan treatment as deemed dividend. On that construction, a loan can be treated as dividend only to the extent of accumulated profits computed without current year profits and after making the relevant deductions and appropriations. en-us Tue, 18 Jan 1972 00:00:00 +0530 Tue, 27 Sep 2016 11:05:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=8425 For section 2(6A)(e) of the Indian Income-tax Act, 1922, accumulated profits mean profits brought forward from prior periods and available for distribution, not profits arising during the current accounting year. The provision for taxation and any declared dividend must be deducted when computing accumulated profits because they reduce the amount actually available for loan treatment as deemed dividend. On that construction, a loan can be treated as dividend only to the extent of accumulated profits computed without current year profits and after making the relevant deductions and appropriations. Case-Laws Income Tax Tue, 18 Jan 1972 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=8425