https://www.taxtmi.com/caselaws?id=289942 Section 23A depended on whether commercial profits were actually available for lawful dividend distribution. For assessment year 1947-48, tax liabilities and outstanding demands substantially reduced distributable profits, so a larger dividend would have been unreasonable and the order was invalid in favour of the assessee. For assessment year 1949-50, profits remained sufficient after taxes, prior payments, and necessary provisions, so the smallness-of-profits condition was not met for the assessee and the order was valid against it. The decision treats "smallness of profits" as commercial profits available for distribution, not notional income, and requires the officer to assess whether a larger dividend would be unreasonable on that basis. en-us Fri, 22 Dec 1961 00:00:00 +0530 Mon, 31 Aug 2020 15:42:11 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=289942 Section 23A depended on whether commercial profits were actually available for lawful dividend distribution. For assessment year 1947-48, tax liabilities and outstanding demands substantially reduced distributable profits, so a larger dividend would have been unreasonable and the order was invalid in favour of the assessee. For assessment year 1949-50, profits remained sufficient after taxes, prior payments, and necessary provisions, so the smallness-of-profits condition was not met for the assessee and the order was valid against it. The decision treats "smallness of profits" as commercial profits available for distribution, not notional income, and requires the officer to assess whether a larger dividend would be unreasonable on that basis. Case-Laws Income Tax Fri, 22 Dec 1961 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=289942