https://www.taxtmi.com/caselaws?id=39903 A liquidation distribution is taxable as dividend only to the extent attributable to accumulated profits immediately before winding up. Section 2(6A)(c), as amended, permits the taxing authority to examine the liquidator's distribution and apportion it between accumulated profits and capital in the proportion existing before liquidation. The provision does not create separate notional funds for each distribution, nor does it limit dividend treatment to amounts first brought to tax in a particular year. The taxable component is therefore determined by proportional allocation, with only the accumulated profits portion treated as dividend. en-us Fri, 07 Oct 1966 00:00:00 +0530 Wed, 13 Aug 2014 17:58:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=39903 A liquidation distribution is taxable as dividend only to the extent attributable to accumulated profits immediately before winding up. Section 2(6A)(c), as amended, permits the taxing authority to examine the liquidator's distribution and apportion it between accumulated profits and capital in the proportion existing before liquidation. The provision does not create separate notional funds for each distribution, nor does it limit dividend treatment to amounts first brought to tax in a particular year. The taxable component is therefore determined by proportional allocation, with only the accumulated profits portion treated as dividend. Case-Laws Income Tax Fri, 07 Oct 1966 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=39903