https://www.taxtmi.com/caselaws?id=23635 For section 23A, the relevant enquiry is the commercial or accounting profit available for distribution, not assessable income. Legitimate outgoings, expenses, sales tax liability and tax payable had to be deducted in computing the distributable surplus, and the Court accepted the Tribunal's finding that no amount remained available for dividend in either assessment year. The principle applied was that "smallness of profits" refers to actual accounting profits judged on commercial principles. Section 23A was therefore not attracted, and the Tribunal's cancellation of the section 23A orders was upheld. en-us Wed, 07 Jun 1989 00:00:00 +0530 Fri, 24 Apr 2015 13:14:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=23635 For section 23A, the relevant enquiry is the commercial or accounting profit available for distribution, not assessable income. Legitimate outgoings, expenses, sales tax liability and tax payable had to be deducted in computing the distributable surplus, and the Court accepted the Tribunal's finding that no amount remained available for dividend in either assessment year. The principle applied was that "smallness of profits" refers to actual accounting profits judged on commercial principles. Section 23A was therefore not attracted, and the Tribunal's cancellation of the section 23A orders was upheld. Case-Laws Income Tax Wed, 07 Jun 1989 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=23635