Current Yr Profit not part of accumulated Profit for 2(22)(e) : Guj HC
In a recent decision, the Hon’ble Gujarat High Court has laid down that Profit for the year till the date of giving of advance in question can not be considered for level of accumulated Profits for the purposes of taxation of deemed dividend u/s 2(22)(e). For this, the Hon’ble Gujarat HC has relied upon the judgement of Associated Banking Corporation of Ind. Ltd. V/s. Commissioner of Income-Tax, Bombay reported in (1965) 56 ITR 1 (SC).
For complete text of judgement, click here Current Profit Not to be considered for 2(22)(e) accumulated profits-Guj HC