https://www.taxtmi.com/caselaws?id=97090 A question of law in a reference under the Indian Income-tax Act must arise from the issues raised before the Appellate Tribunal, so a fresh challenge to the validity of a power of attorney could not be entertained for the first time in reference. The expression "controlling interest" under section 2(21) of the Excess Profits Tax Act, 1940 was construed as control through voting power at a general meeting, not mere beneficial ownership of shares. On the facts, the relevant voting power was exercised through the director-attorney arrangement, so the company was treated as director-controlled and the substantive tax issue was answered in favour of the Revenue. en-us Wed, 17 Jan 1951 00:00:00 +0530 Tue, 27 Dec 2016 17:44:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=97090 A question of law in a reference under the Indian Income-tax Act must arise from the issues raised before the Appellate Tribunal, so a fresh challenge to the validity of a power of attorney could not be entertained for the first time in reference. The expression "controlling interest" under section 2(21) of the Excess Profits Tax Act, 1940 was construed as control through voting power at a general meeting, not mere beneficial ownership of shares. On the facts, the relevant voting power was exercised through the director-attorney arrangement, so the company was treated as director-controlled and the substantive tax issue was answered in favour of the Revenue. Case-Laws Companies Law Wed, 17 Jan 1951 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=97090