https://www.taxtmi.com/caselaws?id=27215 Section 23A turns on a company's real commercial profits shown in its books, not on assessable income computed by artificial tax adjustments. Where earlier dividends had been declared under mercantile accounting and the amount had already been reflected in shareholders' accounts, a later change in accounting method and consequent tax assessment did not convert that sum into fresh distributable profit. The test of smallness of profits had to be applied to actual business profits, and the amount of Rs. 3,30,915 was therefore not available for dividend distribution. The Tribunal was correct in treating the figure as outside commercial profits for section 23A purposes. en-us Mon, 17 Sep 1984 00:00:00 +0530 Thu, 11 Feb 2010 15:36:06 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=27215 Section 23A turns on a company's real commercial profits shown in its books, not on assessable income computed by artificial tax adjustments. Where earlier dividends had been declared under mercantile accounting and the amount had already been reflected in shareholders' accounts, a later change in accounting method and consequent tax assessment did not convert that sum into fresh distributable profit. The test of smallness of profits had to be applied to actual business profits, and the amount of Rs. 3,30,915 was therefore not available for dividend distribution. The Tribunal was correct in treating the figure as outside commercial profits for section 23A purposes. Case-Laws Income Tax Mon, 17 Sep 1984 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=27215