https://www.taxtmi.com/caselaws?id=37872 Capital gains realised on sale of a capital asset were taxable income, but for judging the reasonableness of dividend under section 23A of the Income-tax Act, 1922, the controlling test was commercial profit and not assessable income alone. The Court applied the principle that smallness of profit must be determined on commercial principles. On the facts, the gains were transferred to reserves and not brought into the profit and loss account, so they did not ordinarily form part of distributable business profits. The section 23A order was therefore held not justified. en-us Thu, 11 May 1978 00:00:00 +0530 Thu, 01 Apr 2010 15:27:32 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=37872 Capital gains realised on sale of a capital asset were taxable income, but for judging the reasonableness of dividend under section 23A of the Income-tax Act, 1922, the controlling test was commercial profit and not assessable income alone. The Court applied the principle that smallness of profit must be determined on commercial principles. On the facts, the gains were transferred to reserves and not brought into the profit and loss account, so they did not ordinarily form part of distributable business profits. The section 23A order was therefore held not justified. Case-Laws Income Tax Thu, 11 May 1978 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=37872