https://www.taxtmi.com/caselaws?id=8709 For deemed dividend under section 2(6A)(e) of the Income-tax Act, 1922, development rebate reserves were treated as part of accumulated profits because they were reserves created out of current profits, while initial depreciation reserves were excluded because initial depreciation was regarded as a charge on profits. Mere debit and credit entries for unpaid call monies were not treated as a loan or advance, as the provision required a real payment or advance. The fiction also applied only where the loan was made to a registered shareholder; a Hindu undivided family, as a beneficial owner but not a registered shareholder, fell outside the provision on the facts stated. en-us Fri, 14 Apr 1972 00:00:00 +0530 Wed, 03 Jun 2009 10:35:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=8709 For deemed dividend under section 2(6A)(e) of the Income-tax Act, 1922, development rebate reserves were treated as part of accumulated profits because they were reserves created out of current profits, while initial depreciation reserves were excluded because initial depreciation was regarded as a charge on profits. Mere debit and credit entries for unpaid call monies were not treated as a loan or advance, as the provision required a real payment or advance. The fiction also applied only where the loan was made to a registered shareholder; a Hindu undivided family, as a beneficial owner but not a registered shareholder, fell outside the provision on the facts stated. Case-Laws Income Tax Fri, 14 Apr 1972 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=8709