https://www.taxtmi.com/caselaws?id=38076 An amount added in assessment merely because the genuineness of loan credits was not proved cannot automatically be treated as commercial profit available for dividend distribution under section 23A(1) of the Indian Income-tax Act, 1922. The relevant test is whether real commercial profits were available after applying ordinary commercial accounting principles, and that requires independent material showing distributable surplus. In the absence of such material, the deemed addition for assessment purposes did not justify including the sum in commercial profits, so section 23A(1) was not attracted. en-us Fri, 27 Jan 1978 00:00:00 +0530 Sat, 03 Apr 2010 10:35:34 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=38076 An amount added in assessment merely because the genuineness of loan credits was not proved cannot automatically be treated as commercial profit available for dividend distribution under section 23A(1) of the Indian Income-tax Act, 1922. The relevant test is whether real commercial profits were available after applying ordinary commercial accounting principles, and that requires independent material showing distributable surplus. In the absence of such material, the deemed addition for assessment purposes did not justify including the sum in commercial profits, so section 23A(1) was not attracted. Case-Laws Income Tax Fri, 27 Jan 1978 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=38076