MESSRS. DHANDHANIA KEDIA & CO. vs THE COMMISSIONER OF INCOME-TAX

The Supreme Court held that the distribution of accumulated profits during the six financial years preceding liquidation constitutes 'dividend' under Section 2(6A)(c) of the Indian Income-tax Act, 1922. The appellant's argument that 'previous years' should align with the definition in Section 2(1) was rejected, affirming that the term refers to the financial years prior to liquidation. Consequently, the sum received by the appellant was deemed taxable as dividend, and the appeal was dismissed.