Section 2(22)(e) IT Act: Deemed Dividends Include All Accumulated Profits Until Payment Date Without Year Distinction.

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....Additions u/s 2(22)(e) on account of deemed dividend - Accumulated profit - As per the provision of Explanation 2, all the profits of the company up to the date of distribution or payment under section 2(22)(e) of the Act shall be considered as accumulated profits. Thus, the provision of Explanation 2 to section 2(22) of the Act does not distinguish between the profit accumulated in the immediately preceding year and the current year profit, and takes within its ambit all the profits up to the date of payment. - AT....