https://www.taxtmi.com/caselaws?id=276438 A deemed dividend under section 22 of the East African Income Tax (Management) Act, 1952 created a limited fiction only for taxing undistributed company profits and could not be carried into section 24. Section 24 applied only where income was actually paid to or for the benefit of a child under a settlement, so the natural meaning of "paid" could not be expanded by the section 22 deeming rule. The provisions were treated as independent charging provisions, and the fiction for one could not alter the operation of the other. The deemed dividend was therefore not a payment within section 24, and the assessments had to be amended. en-us Thu, 12 Nov 1959 00:00:00 +0530 Mon, 12 Nov 2018 10:51:44 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=276438 A deemed dividend under section 22 of the East African Income Tax (Management) Act, 1952 created a limited fiction only for taxing undistributed company profits and could not be carried into section 24. Section 24 applied only where income was actually paid to or for the benefit of a child under a settlement, so the natural meaning of "paid" could not be expanded by the section 22 deeming rule. The provisions were treated as independent charging provisions, and the fiction for one could not alter the operation of the other. The deemed dividend was therefore not a payment within section 24, and the assessments had to be amended. Case-Laws Income Tax Thu, 12 Nov 1959 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=276438