https://www.taxtmi.com/caselaws?id=39840 For deemed dividend under section 2(6A)(e) of the Indian Income-tax Act, 1922, accumulated profits are to be determined as on the date the loan or advance is paid to the shareholder, and only to that extent can the payment be treated as dividend. A later declaration of dividend does not reduce the amount already characterisable as deemed dividend, because clause (iii) contemplates only a set-off against an amount previously brought to tax under clause (e). Accumulated profits may arise within a single year and need not be carried forward from year to year. The relevant distributable profits were therefore those available when the loan was made. en-us Tue, 11 Sep 1973 00:00:00 +0530 Tue, 20 Apr 2010 16:14:35 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=39840 For deemed dividend under section 2(6A)(e) of the Indian Income-tax Act, 1922, accumulated profits are to be determined as on the date the loan or advance is paid to the shareholder, and only to that extent can the payment be treated as dividend. A later declaration of dividend does not reduce the amount already characterisable as deemed dividend, because clause (iii) contemplates only a set-off against an amount previously brought to tax under clause (e). Accumulated profits may arise within a single year and need not be carried forward from year to year. The relevant distributable profits were therefore those available when the loan was made. Case-Laws Income Tax Tue, 11 Sep 1973 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=39840