https://www.taxtmi.com/caselaws?id=29608 Liquidation receipts were not taxable as deemed dividend under section 2(22)(c) because the distribution was made only after statutory compensation for the undertaking had been determined and the reserve amounts had already been deducted from that compensation. On those facts, the sums paid to the assessee were not shown to be attributable to accumulated profits immediately before liquidation. The deemed-dividend provision had to be construed strictly, and the wider question whether the reserves themselves formed part of accumulated profits was unnecessary to decide on the facts found. The receipts were therefore not income under section 2(22)(c). en-us Wed, 01 Oct 1980 00:00:00 +0530 Mon, 15 Mar 2010 11:02:34 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=29608 Liquidation receipts were not taxable as deemed dividend under section 2(22)(c) because the distribution was made only after statutory compensation for the undertaking had been determined and the reserve amounts had already been deducted from that compensation. On those facts, the sums paid to the assessee were not shown to be attributable to accumulated profits immediately before liquidation. The deemed-dividend provision had to be construed strictly, and the wider question whether the reserves themselves formed part of accumulated profits was unnecessary to decide on the facts found. The receipts were therefore not income under section 2(22)(c). Case-Laws Income Tax Wed, 01 Oct 1980 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=29608