COMMISSIONER OF INCOME-TAX, CALCUTTA vs NALIN BEHARI LAL SINGHA ETC.

The Supreme Court held that under Section 2(6A) of the Income-tax Act, 1922, capital gains arising after March 31, 1948, are not considered 'dividend' for tax purposes. The Court dismissed the appeal, affirming that only the portion of the distribution representing accumulated profits is taxable, while capital gains are explicitly excluded from the definition of dividend. The High Court's ruling in favor of the assessee was upheld, confirming the exemption of the disputed dividend from income tax.