https://www.taxtmi.com/caselaws?id=39473 Amounts appropriated to statutory reserves remained accumulated profits because they were made out of profits, were not capitalised, and were not transferred to any separate fund vesting in a third party; the company's profit for the year ending 31 March 1956 was treated on the same footing, and the accumulated-profits finding went against the assessee. Distribution of liquidation proceeds was not assessable as capital gains for assessment years 1960-61 and 1961-62, because section 12B of the 1922 Act required a sale, exchange, relinquishment or transfer, which liquidation distribution did not involve. For 1962-63, section 46(2) of the 1961 Act applied as an express charging provision, so the distribution was liable to capital gains tax for that year. en-us Mon, 22 Jul 1974 00:00:00 +0530 Fri, 16 Apr 2010 16:17:53 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=39473 Amounts appropriated to statutory reserves remained accumulated profits because they were made out of profits, were not capitalised, and were not transferred to any separate fund vesting in a third party; the company's profit for the year ending 31 March 1956 was treated on the same footing, and the accumulated-profits finding went against the assessee. Distribution of liquidation proceeds was not assessable as capital gains for assessment years 1960-61 and 1961-62, because section 12B of the 1922 Act required a sale, exchange, relinquishment or transfer, which liquidation distribution did not involve. For 1962-63, section 46(2) of the 1961 Act applied as an express charging provision, so the distribution was liable to capital gains tax for that year. Case-Laws Income Tax Mon, 22 Jul 1974 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=39473