By the said order the Income tax Officer held that Rs.
6,509.
The balance sheet of the respondent disclosed past losses amounting to Rs.
116 of 1960.
10,151 on account of grossing up of dividends and interest on securities.
In respect of the said assessment year the Income tax Officer made an order dated March 15, 1956, under section 23A 1 of the Income tax Act, 1922 hereinafter referred to as the Act .
35,476 should be deemed as having been distributed as dividend by the respondent and the proportionate share thereof of each shareholder should be included in the total income of such shareholder for the purpose of assessing his total income.
The Income tax Officer recomputed the losses of the respondent in earlier years by valuing the bonus shares received by the respondent at nil and, accordingly, held that the losses amounted to Rs.
45,692 which had been brought forward.
The relevant assessment year is 1950 51 and the companyresponding previous year ended on March 31, 1950.
The Income tax Officer held that such losses resulted from the failure of the respondent in number properly accounting for some bonus shares received by it.
The aforesaid companyputation was made mainly by disallowing Rs.
Ramaswami J. This appeal is brought from the judgment o the Calcutta High Court dated March 10, 1964, in Income tax Reference No.
