https://www.taxtmi.com/caselaws?id=59332 Advances made to a concern in which common shareholders held substantial interest were treated as capable of falling within the deemed dividend fiction under section 2(22)(e); the character of the payment as a trade advance did not, by itself, exclude the provision. Accumulated profits for that purpose had to be computed up to the date of distribution or payment under Explanation 2, and the matter was remitted for recomputation because the record did not clearly show calculation on the correct date. The section 68 cash-credit addition was set aside for fresh adjudication because the enquiry into identity, genuineness, and creditworthiness was incomplete and adequate opportunity had not been given. The connected rectification issue was also sent back for reconsideration. en-us Fri, 31 Mar 2006 00:00:00 +0530 Wed, 13 Mar 2024 13:12:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=59332 Advances made to a concern in which common shareholders held substantial interest were treated as capable of falling within the deemed dividend fiction under section 2(22)(e); the character of the payment as a trade advance did not, by itself, exclude the provision. Accumulated profits for that purpose had to be computed up to the date of distribution or payment under Explanation 2, and the matter was remitted for recomputation because the record did not clearly show calculation on the correct date. The section 68 cash-credit addition was set aside for fresh adjudication because the enquiry into identity, genuineness, and creditworthiness was incomplete and adequate opportunity had not been given. The connected rectification issue was also sent back for reconsideration. Case-Laws Income Tax Fri, 31 Mar 2006 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=59332