https://www.taxtmi.com/caselaws?id=196777 Where a company carries on a composite business, dividend distribution under Section 23A and Explanation 2 of the Income-tax Act, 1922 had to be apportioned between industrial and non-industrial profits in the same ratio as those profits bore to total profits; the company could not choose a different basis, and the prescribed ratio was mandatory. The statutory fiction in Explanation 2 applied only to determine the minimum dividend requirement for each segment. Once a shortfall arose, additional super-tax was leviable on the entire undistributed balance of the company's distributable profits, not merely on the balance attributable to the defaulting segment. The Revenue's position was accepted. en-us Wed, 09 Apr 1975 00:00:00 +0530 Thu, 14 Dec 2017 13:25:08 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=196777 Where a company carries on a composite business, dividend distribution under Section 23A and Explanation 2 of the Income-tax Act, 1922 had to be apportioned between industrial and non-industrial profits in the same ratio as those profits bore to total profits; the company could not choose a different basis, and the prescribed ratio was mandatory. The statutory fiction in Explanation 2 applied only to determine the minimum dividend requirement for each segment. Once a shortfall arose, additional super-tax was leviable on the entire undistributed balance of the company's distributable profits, not merely on the balance attributable to the defaulting segment. The Revenue's position was accepted. Case-Laws Income Tax Wed, 09 Apr 1975 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=196777