https://www.taxtmi.com/caselaws?id=49261 For section 23A of the Income-tax Act, 1922, the relevant basis for deeming dividend distribution is the real commercial profit, not merely the figures in the books. Concealed receipts and deliberately omitted items may be added to book profits to determine the true amount reasonably distributable as dividend. A contention based on earlier losses and business considerations was not entertained because it had not been raised before the income-tax authorities and the necessary facts were not on record. On the facts, the statutory threshold was not met and a larger dividend could reasonably have been declared, so section 23A applied. en-us Thu, 16 Dec 1965 00:00:00 +0530 Sun, 17 Aug 2014 14:48:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=49261 For section 23A of the Income-tax Act, 1922, the relevant basis for deeming dividend distribution is the real commercial profit, not merely the figures in the books. Concealed receipts and deliberately omitted items may be added to book profits to determine the true amount reasonably distributable as dividend. A contention based on earlier losses and business considerations was not entertained because it had not been raised before the income-tax authorities and the necessary facts were not on record. On the facts, the statutory threshold was not met and a larger dividend could reasonably have been declared, so section 23A applied. Case-Laws Income Tax Thu, 16 Dec 1965 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=49261