https://www.taxtmi.com/caselaws?id=7719 Section 23A applies only where the statutory conditions for treating a company as one in which the public were substantially interested are not met. Mere family relationship among shareholders does not by itself prove that they were acting in concert; the revenue must show concerted action or other material demonstrating that the public interest requirement is not satisfied. The Tribunal's finding that such proof was lacking was treated as a factual conclusion based on the evidence, and no perversity or legal error was shown. The tribunal also acted lawfully in proceeding on the material before it without taking further evidence, so section 23A was held inapplicable. en-us Fri, 14 Mar 1969 00:00:00 +0530 Wed, 18 Mar 2009 09:58:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=7719 Section 23A applies only where the statutory conditions for treating a company as one in which the public were substantially interested are not met. Mere family relationship among shareholders does not by itself prove that they were acting in concert; the revenue must show concerted action or other material demonstrating that the public interest requirement is not satisfied. The Tribunal's finding that such proof was lacking was treated as a factual conclusion based on the evidence, and no perversity or legal error was shown. The tribunal also acted lawfully in proceeding on the material before it without taking further evidence, so section 23A was held inapplicable. Case-Laws Income Tax Fri, 14 Mar 1969 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=7719