Section 23A to the extent relevant for our present purpose reads : " (1) Where the Income Tax Officer is satisfied that in respect of any previous year the profits and gains distributed as dividends by any company within the twelve months immediately following the expiry of that pre vious year are less than the statutory percentage of the total income of the company of that previous year as reduced by (a). . . . . . (b). . . . . . . (c). . . . . 730 The Income tax Officer shall, unless he is satisfied that, having regard to the losses incurred by the company, in earlier years or to the smallness of the profits made in the previous year, the payment of a dividend or a larger dividend than, that declared would be unreasonable, make an order in writing that the company shall, apart from the sum determined as payable by it on the basis of the assessment under section 23, be liable to pay super tax at the rate of fifty per cent.