Dismissing the appeal of the Revenue the Court held  that  final difference in rate  although paid at the end of the previous year the amount was paid only to the milk suppliers, for the quantity of milk supplied and in terms of the quality supplied. The amount was not paid to all the shareholders and was not paid out of the profits ascertained at the annual general meeting. The amount paid to the milk suppliers and to non-members could not be said to be an appropriation of the profits. Order of High Court, affirmed.