https://www.taxtmi.com/caselaws?id=38747 For section 23A, the reasonableness of dividend distribution is assessed by reference to the commercial profits of the relevant previous year, not by adding accumulated profits brought forward from earlier years; earlier undistributed profits could not be treated as part of the statutory inquiry, and the subsidiary-liquidator receipt did not alter that position. For a company whose business consisted wholly or mainly in holding investments, the applicable statutory percentage under section 23A was 90%, not 65%. The principal controversy was resolved in favour of the assessee, while the percentage question was decided in favour of the revenue. en-us Thu, 15 Apr 1976 00:00:00 +0530 Thu, 08 Apr 2010 17:19:33 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=38747 For section 23A, the reasonableness of dividend distribution is assessed by reference to the commercial profits of the relevant previous year, not by adding accumulated profits brought forward from earlier years; earlier undistributed profits could not be treated as part of the statutory inquiry, and the subsidiary-liquidator receipt did not alter that position. For a company whose business consisted wholly or mainly in holding investments, the applicable statutory percentage under section 23A was 90%, not 65%. The principal controversy was resolved in favour of the assessee, while the percentage question was decided in favour of the revenue. Case-Laws Income Tax Thu, 15 Apr 1976 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=38747