https://www.taxtmi.com/caselaws?id=276009 For section 2(6A)(c) of the Income-tax Act the six previous years are the six accounting years immediately preceding liquidation, here the calendar years 1943-1948. The provision applies only to accumulated profits that remain uncapitalised; where profits have been appropriated to capital they cease to be distributable accumulated profits for the purpose of that clause. Accordingly, the sum transferred to the capital account on 5 December 1946 is not "accumulated profits" under section 2(6A)(c) and is excluded from taxation as dividend under that provision. en-us Tue, 15 Feb 1955 00:00:00 +0530 Thu, 25 Oct 2018 11:51:28 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=276009 For section 2(6A)(c) of the Income-tax Act the six previous years are the six accounting years immediately preceding liquidation, here the calendar years 1943-1948. The provision applies only to accumulated profits that remain uncapitalised; where profits have been appropriated to capital they cease to be distributable accumulated profits for the purpose of that clause. Accordingly, the sum transferred to the capital account on 5 December 1946 is not "accumulated profits" under section 2(6A)(c) and is excluded from taxation as dividend under that provision. Case-Laws Income Tax Tue, 15 Feb 1955 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=276009