1978 (2) TMI 22

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..... on the facts and in the circumstances of the case, the Tribunal was right in law in holding that there were no accumulated profits of the company as on April 1, 1960 and no amount could be brought to tax under the provisions of section 2(6A)(e) of the Indian Income-tax Act, 1922 ? " It is admitted that the loan was given to the HUFs, who are shown as respondents in this tax case. The shareholde .....

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..... held that development rebate reserve will also be accumulated profit, that question does not arise for consideration in view of our answer to the latter part of the question referred. We, therefore, do not propose to answer the first part of the question, as it is academic. So, we hold that the four HUFs, who are the assessees, could not be taxed on any deemed income under s. 2(6A)(e). The questi .....

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