1968 (6) TMI 3

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..... the court was delivered by VEERASWAMI J.- The short point in this reference is whether distributable profit for purposes of section 23A of the Indian Income-tax Act, 1922, would include notional dividend. We are concerned with the assessment year 1955-56. The assessee is a private limited company which was regularly assessed for that year in February 1956, on a total income of Rs. 67,680. Later .....

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..... for actual distribution. A notional dividend is not an actual receipt. It may be that it may form part of the total income for purposes of assessment, but we do not think that, for purpose of section 23A, it can be so regarded, for what it contemplates is distribution of profit, which implies that the assessee actually has in its hands of the income or profit. In this sense notional dividend may d .....

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