https://www.taxtmi.com/caselaws?id=49629 A liquidation distribution was treated as dividend under section 2(6A)(c) of the Indian Income-tax Act, 1922 because the phrase "six previous years" was construed contextually, not in the technical sense of "previous year" in section 2(11). The provision was read to cover the six accounting years immediately preceding liquidation, which preserved the legislative purpose of assimilating distributions of accumulated profits on liquidation to dividend while limiting the charge to profits accumulated during that period. On that construction, the liquidator's distribution of accumulated profits was taxable, and the contrary argument based on section 2(11) failed. en-us Fri, 17 Oct 1958 00:00:00 +0530 Thu, 11 Jan 2018 16:59:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=49629 A liquidation distribution was treated as dividend under section 2(6A)(c) of the Indian Income-tax Act, 1922 because the phrase "six previous years" was construed contextually, not in the technical sense of "previous year" in section 2(11). The provision was read to cover the six accounting years immediately preceding liquidation, which preserved the legislative purpose of assimilating distributions of accumulated profits on liquidation to dividend while limiting the charge to profits accumulated during that period. On that construction, the liquidator's distribution of accumulated profits was taxable, and the contrary argument based on section 2(11) failed. Case-Laws Income Tax Fri, 17 Oct 1958 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=49629