chargeable to tax under section 115BAD of the Income-tax Act: Provided further that in respect of any income chargeable to tax under section 115A ... section 2 of the Income-tax Act, having income under section 115AD of the Income-tax Act,–– the Income-tax Act] exceeding five crore rupees
income
that is taxed but it is not taxed in vacuo. It is taxed in the hands of
a person."12 Section ... shareholder by a Company which was assessed to
tax, the income tax in respect of such dividend was deemed to have
been paid
tax payable by him of a sum calculated on such doubly taxed income at the Indian rate of tax or the rate of tax ... tax appropriate thereto (rule 20 of the All Schedules Rules, Income Tax Act, 1918). When a company declares a tax-free dividend, it is regarded
declaration of any dividend; or
(b) distribution of any dividend; or
(c) payment of any dividend,
whichever is earliest.
(4) The tax on distributed profits ... which deals with “Collection and
Recovery of Tax” including tax on dividend income received by a
shareholder. It may be convenient, to appreciate what
tax payable by him; (iv) a sum
calculated on such doubly taxed income at the Indian rate of
tax or the rate of tax ... Tax Cases 603 at 636
(2) 27 Tax Cases 205.
(3) 40 Tax Cases 176 at 205.
(4) 41 Tax Casts 666.
852
that
company which is assessed to tax, the
income-tax (but not super-tax) in respect of such dividend
is deemed to have been paid ... company which is assessed to tax, the
income-tax (but not super-tax) in respect of such dividend
is deemed to have been paid
certain dividends were declared and subsequently paid in the manner and to the extent indicated below:
Gross Ceylon Net Dividend
dividends. income-tax dividends. certificates ... tax appropriate thereto (rule 20 of the All Schedules Rules, Income-tax Act, 1918). When a company declares a tax free dividend, it is regarded
tax on its profits and pays the tax direct. There is no express provision enabling a company which has paid tax to deduct from dividends ... dividends. But if the company pays income-tax and cannot deduct the tax paid from the dividends they would in fact be tax-free, since
debts 10,17,481
(iii) Surtax reserve 20,83,115
(iv) Dividend tax reserve 7,50,000
(v) Retirement gratuity reserve ... imposing tax on dividends came into effect on April 28, 1964. The actual liability on account of dividend tax which has been imposed
CIT -vs. - B.C. Srinivasa Shetty
(1981) 128 ITR 294 (SC) held that under the scheme of Income-tax
Act, 1961 charge of tax will ... thereby the deemed
dividend would not be deemed dividend in the hands of the firm, rather it
would obviously be deemed dividend in the hands
