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    <title>1973 (9) TMI 46 - MADRAS High Court</title>
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    <description>Section 23A of the Indian Income-tax Act, 1922 was held inapplicable where, on the material proved before the Tribunal, the declared dividends could not be said to be unreasonable having regard to the commercial profits available for distribution. The Tribunal accepted the relevant profit figures and found that the revenue&#039;s proposed adjustments, including alleged additional reserve and excess depreciation, were not established as necessary deductions or additions for computing commercial surplus. The governing test was the commercial profit available for distribution on the evidence before the Tribunal, not unsupported additions to book figures. On that basis, the assessee succeeded and the Tribunal&#039;s view was sustained.</description>
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    <pubDate>Mon, 24 Sep 1973 00:00:00 +0530</pubDate>
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      <title>1973 (9) TMI 46 - MADRAS High Court</title>
      <link>https://www.taxtmi.com/caselaws?id=39818</link>
      <description>Section 23A of the Indian Income-tax Act, 1922 was held inapplicable where, on the material proved before the Tribunal, the declared dividends could not be said to be unreasonable having regard to the commercial profits available for distribution. The Tribunal accepted the relevant profit figures and found that the revenue&#039;s proposed adjustments, including alleged additional reserve and excess depreciation, were not established as necessary deductions or additions for computing commercial surplus. The governing test was the commercial profit available for distribution on the evidence before the Tribunal, not unsupported additions to book figures. On that basis, the assessee succeeded and the Tribunal&#039;s view was sustained.</description>
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      <pubDate>Mon, 24 Sep 1973 00:00:00 +0530</pubDate>
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