... ... ... ... s not attracted at all in the case of a company which has not declared any dividend. For the reasons stated above, the question referred will have to be necessarily answered in the affirmative and against the Revenue. References answered accordingly.
... ... ... ... n the judgments mentioned above. For the reasons recorded above, the rule is made absolute and the impugned orders passed by the Board and the Income-tax Officer are hereby quashed. In the circumstances, the parties are left to bear their own costs.
... ... ... ... essee had to incur, declaration of dividend of more than Rs. 75,000 would be unreasonable. In the above view of the matter, the orders of the authorities below are set aside. The assessee is not liable to pay additional tax. 7. The appeal is allowed.