https://www.taxtmi.com/caselaws?id=14408 The Interest-tax Act, 1974 was treated as a levy on gross receipts of interest, not on income, so section 32 of the Unit Trust of India Act, 1963 did not bar its application to UTI; the later special fiscal enactment prevailed to the extent of any overlap. The CBDT communication withdrawing the earlier 1991 view was held to operate prospectively, because UTI had relied on that position and altered its conduct accordingly. Notices under section 10(a) for non-filing of returns were invalid on the facts, as the omission arose from the binding administrative position then in force and not from an actionable failure. en-us Thu, 19 Apr 2001 00:00:00 +0530 Mon, 22 Dec 2025 14:29:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=14408 The Interest-tax Act, 1974 was treated as a levy on gross receipts of interest, not on income, so section 32 of the Unit Trust of India Act, 1963 did not bar its application to UTI; the later special fiscal enactment prevailed to the extent of any overlap. The CBDT communication withdrawing the earlier 1991 view was held to operate prospectively, because UTI had relied on that position and altered its conduct accordingly. Notices under section 10(a) for non-filing of returns were invalid on the facts, as the omission arose from the binding administrative position then in force and not from an actionable failure. Case-Laws Income Tax Thu, 19 Apr 2001 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=14408