https://www.taxtmi.com/caselaws?id=35907 For surtax capital computation under the Companies (Profits) Surtax Act, 1964, the relevant date remained the first day of the previous year, and the character of a proposed dividend depended on the substance of the company's accounts and linked transactions. Where the creation of general reserve, proposal of dividend, and later shareholder ratification formed one integrated transaction, the subsequent declaration could relate back to the opening of the accounting year. On that footing, the proposed dividend was not treated as part of the reserve available for capital computation, and the Tribunal's finding was not shown to be unsupported by evidence or perverse. en-us Thu, 07 Aug 1980 00:00:00 +0530 Wed, 17 Mar 2010 17:33:28 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=35907 For surtax capital computation under the Companies (Profits) Surtax Act, 1964, the relevant date remained the first day of the previous year, and the character of a proposed dividend depended on the substance of the company's accounts and linked transactions. Where the creation of general reserve, proposal of dividend, and later shareholder ratification formed one integrated transaction, the subsequent declaration could relate back to the opening of the accounting year. On that footing, the proposed dividend was not treated as part of the reserve available for capital computation, and the Tribunal's finding was not shown to be unsupported by evidence or perverse. Case-Laws Income Tax Thu, 07 Aug 1980 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=35907