Deemed Dividend Income: Security Premium Reserve Excluded from Accumulated Profits u/s 2(22)(e) of Income Tax Act.

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....Addition u/s 2(22)(e) - deemed dividend of income - the security premium reserve cannot be regarded as part of accumulated profits u/s 2(22)(e) and when such security premium is excluded, the General Reserve available for the purposes of addition under Section 2(22)(e) only and thus sustained the addition to the extent accumulated profit excluding share premium reserve. - AT....