https://www.taxtmi.com/caselaws?id=184632 Section 23A was construed broadly and not as limited to business income alone. The Calcutta HC treated the classification of income under Section 6 as a computation method, not a basis for excluding a company whose income was wholly assessable under Section 9 from the section's scope. It also rejected the argument that notional property income could not be distributed in practice, noting that the statutory language contained no exclusion for property companies and allowed discretion where profits were small. On that analysis, Section 23A was held applicable to the company, and the question was answered in favour of the Revenue. en-us Mon, 06 Sep 1948 00:00:00 +0530 Thu, 14 Jul 2016 17:31:19 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=184632 Section 23A was construed broadly and not as limited to business income alone. The Calcutta HC treated the classification of income under Section 6 as a computation method, not a basis for excluding a company whose income was wholly assessable under Section 9 from the section's scope. It also rejected the argument that notional property income could not be distributed in practice, noting that the statutory language contained no exclusion for property companies and allowed discretion where profits were small. On that analysis, Section 23A was held applicable to the company, and the question was answered in favour of the Revenue. Case-Laws Income Tax Mon, 06 Sep 1948 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=184632