Ajax Products Ltd. was a public limited companypany incorporated in 1939.
The Company went into liquidation on October 31, 1954.
Jagadish Swarup, Solicitor General, G. C. Sharma and B. D. Sharma, for the appellant.
The liquidators of the Company distributed on March 10, 1955 to the shareholders for each share Rs.
Appeal from the judgment and order dated November 18, 1965 of the Madras High Court in Tax Case No.
Between January 1, 1954 and October 31, 1954 the Company earned a profit of Rs.
1,79,704.
The respondents to this appeal were share holders of the Company.
CIVIL APPELLATE JURISDICTION Civil Appeal No.
The Commissioner of Income tax asked for and obtained a certificate from the High Court only in respect of the amount of Rs.
81,61 1.
1 to 10.
81,611 was number part of the accumulated profits of the Company as on October 31, 1954 as companytemplated by s. 2 6A c of the Income tax Act.
Srinivasan and R., Gopalakrishnan, for respondents Nos.
100 by allotment of a share in Carborurndum Universal Ltd. of the same face value.
1,491,444 were number the part of the accumulated profits of the Company as on December 31, 1954 as companytemplated under s. 2 6A c of the Income tax Act of 1922 The High Court answered the question in the affirmative.
It maintained its accounts according to the calendar year.
The judgment of the Court was delivered by Shah, J. Income tax Appellate Tribunal submitted the under s. 66 1 of the Indian Income tax Act, Court of Madras for opinion Whether on the facts and in the circumstances of the case the Tribunal was right in holding that the sum of Rs.
162 of 1963.
81,611 and Rs.
566 of 1967.
This order was companyfirmed by the Tribunal.
