https://www.taxtmi.com/caselaws?id=8503 For dividend purposes under section 2(6A)(c), surplus on sale of tea estates was treated as capital appreciation, not trading profit, so only the amount actually assessed as capital gains could enter accumulated profits. Revaluation reserves were given the same treatment as the underlying capital surplus. By contrast, balances standing in the profit and loss account and general reserves were commercial profits finally appropriated in the accounts, and were not to be split again into agricultural and non-agricultural elements under the tea income apportionment rule. The result was that those balances were wholly includible in accumulated profits, while the sale surplus was includible only to the extent of assessed capital gains. en-us Wed, 13 Jan 1971 00:00:00 +0530 Mon, 27 Apr 2009 17:10:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=8503 For dividend purposes under section 2(6A)(c), surplus on sale of tea estates was treated as capital appreciation, not trading profit, so only the amount actually assessed as capital gains could enter accumulated profits. Revaluation reserves were given the same treatment as the underlying capital surplus. By contrast, balances standing in the profit and loss account and general reserves were commercial profits finally appropriated in the accounts, and were not to be split again into agricultural and non-agricultural elements under the tea income apportionment rule. The result was that those balances were wholly includible in accumulated profits, while the sale surplus was includible only to the extent of assessed capital gains. Case-Laws Income Tax Wed, 13 Jan 1971 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=8503