Provisions of Deemed Dividend not applicable to Capital Subsidy/Grant

Shri Vinod Kumar Mittal Vs ITO (ITAT Jaipur) The provision of S. 2(22)(e) along with its Explanations – 2 as stood at the relevant point of time, shall only mean that the expression “accumulated profits” shall only include all the profits of the company up to the date of distribution which are normal revenue profits. The words used are plain, clear and unambiguous that only the profits of the company are to be considered for this purpose. The said provision nowhere indicates that capital subsidy/grant should also be included/ considered within the expression “accumulated profit...