https://www.taxtmi.com/caselaws?id=49232 In liquidation, profits earned by a company up to immediately before the commencement of liquidation were treated as accumulated profits and, when distributed by the liquidator, were taxable as dividend. By contrast, capital appreciation realised on the sale of agricultural lands did not fall within accumulated profits, and because it was not chargeable as capital gains, its distribution could not be taxed as dividend. The exemption relating to agricultural income was irrelevant to that issue, because the receipt was characterised as non-dividend capital appreciation rather than exempt dividend income. The demand was therefore sustainable only to the extent it related to current profits and failed for the non-taxable capital appreciation. en-us Wed, 15 Dec 1965 00:00:00 +0530 Mon, 03 Nov 2025 17:55:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=49232 In liquidation, profits earned by a company up to immediately before the commencement of liquidation were treated as accumulated profits and, when distributed by the liquidator, were taxable as dividend. By contrast, capital appreciation realised on the sale of agricultural lands did not fall within accumulated profits, and because it was not chargeable as capital gains, its distribution could not be taxed as dividend. The exemption relating to agricultural income was irrelevant to that issue, because the receipt was characterised as non-dividend capital appreciation rather than exempt dividend income. The demand was therefore sustainable only to the extent it related to current profits and failed for the non-taxable capital appreciation. Case-Laws Income Tax Wed, 15 Dec 1965 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=49232