Supreme Court of India
The Commissioner of Income-tax, Madras v. Urmila Ramesh
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From the headnote
Income Tax Act, 1961 : Ss. 2(22)(c), 32(/)(iii) and 41 (2)-Assessees-shareholders of company Liquidation-Amount realized on sale of assets in excess of written down value but less than purchase price-Distribution of dividends to shareholders-Assessment order treating the sale amount as "accumulated profit" and its distribution to shareholders as "deemed dividend"-Validity of-Held, amount received by the company on sale of assets does not constitute" accumulated profit"-Return of capital on sale of assets is not capable of being capitalised and hence is not "deemed dividend"-Jncome Tax Act,
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