Deemed Dividends Classification Upheld: Tax Authorities' Assessment of Accumulated Profits Valid Despite New Accounting Changes.

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....Deemed dividend u/s 2(22)(d) - Determination of accumulated profit - we are inclined to follow the accumulated loss declared by the Novateur India in their reinstated balance sheet as the proper accumulated loss based on the new set of accounting method and policies adopted by them and it is not mere comparative figures. Hence, the accumulated profit determined by the tax authorities are proper and the determination of dividend as per section 2(22)(d) is proper, accordingly sustain their findings - AT....