https://www.taxtmi.com/caselaws?id=27523 An addition made under section 68 for failure to prove the genuineness and source of hundi loans is not, by that reason alone, commercial profit available for dividend distribution under section 104. Where there is no finding of deliberate inflation of expenditure or proof that the credited amount represents real business surplus, the sum remains artificial, notional, or fictional income rather than distributable profit. On those facts, section 104 did not apply, and the reference was answered in favour of the assessee. en-us Fri, 02 Dec 1983 00:00:00 +0530 Sat, 13 Feb 2010 13:29:58 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=27523 An addition made under section 68 for failure to prove the genuineness and source of hundi loans is not, by that reason alone, commercial profit available for dividend distribution under section 104. Where there is no finding of deliberate inflation of expenditure or proof that the credited amount represents real business surplus, the sum remains artificial, notional, or fictional income rather than distributable profit. On those facts, section 104 did not apply, and the reference was answered in favour of the assessee. Case-Laws Income Tax Fri, 02 Dec 1983 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=27523