( 1 ) THIS is a reference under sec. 66 (1) of the Indian Income Tax Act 1922 The assessment year with which were concerned is the 1955-56 the accounting year being the calendar year 1954. The assessee were shareholders in a company incorporated in accordance with the law prevailing in East Africa called Kawampe Cotton Co. Ltd. Kampala. Having regard to the provisions contained in the Indian Income Tax Act 1922 this company was regarded as a company for the purpose of the Indian Income Tax Act. This company went into voluntary liquidation on 22nd July 1954. In the month of August 1954 the liquidator of the company made payments to the assessees who were the share-holders in that company. The amounts paid to the assessees were received by the assessees on 27th August 1954. The following tabular statement shows the names of the assessees the number of shares of the company held by them. the amount received by them referable to the share capital the amounts received by them referable to capital profit the amount of accumulated profits treated as dividend the amount of total distribution and the amounts referable to accumulated profits of six previous years of the compan