https://www.taxtmi.com/caselaws?id=152203 Section 23A could still be applied after rebate had been granted in the assessment, because the rebate did not amount to a final ruling that the provision was inapplicable, and the statutory conditions could be examined on their merits. For determining whether a company was one in which the public were substantially interested, the public had to hold the requisite voting power beneficially and unconditionally. A cohesive controlling group, including managing agents and persons under their control, could not be treated as the public merely because some members were directors or related persons. On the facts, the company fell within section 23A. en-us Mon, 17 Sep 1962 00:00:00 +0530 Fri, 20 Dec 2024 14:40:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=152203 Section 23A could still be applied after rebate had been granted in the assessment, because the rebate did not amount to a final ruling that the provision was inapplicable, and the statutory conditions could be examined on their merits. For determining whether a company was one in which the public were substantially interested, the public had to hold the requisite voting power beneficially and unconditionally. A cohesive controlling group, including managing agents and persons under their control, could not be treated as the public merely because some members were directors or related persons. On the facts, the company fell within section 23A. Case-Laws Income Tax Mon, 17 Sep 1962 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=152203