https://www.taxtmi.com/caselaws?id=15440 During the currency of the Companies (Temporary Restrictions on Dividends) Act, 1974, additional income-tax under section 104 of the Income-tax Act, 1961 could not be levied for shortfall in dividend distribution. The special dividend-restriction regime, supported by an overriding clause, was inconsistent with the revenue-protective purpose of section 104 and therefore suspended its operation for the relevant period. The later insertion of section 5A did not restore the application of section 104, because it still maintained restrictions on dividend payment during that period. No additional income-tax was consequently leviable on that footing. en-us Mon, 22 Nov 1999 00:00:00 +0530 Thu, 06 Aug 2009 15:53:55 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=15440 During the currency of the Companies (Temporary Restrictions on Dividends) Act, 1974, additional income-tax under section 104 of the Income-tax Act, 1961 could not be levied for shortfall in dividend distribution. The special dividend-restriction regime, supported by an overriding clause, was inconsistent with the revenue-protective purpose of section 104 and therefore suspended its operation for the relevant period. The later insertion of section 5A did not restore the application of section 104, because it still maintained restrictions on dividend payment during that period. No additional income-tax was consequently leviable on that footing. Case-Laws Income Tax Mon, 22 Nov 1999 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=15440