https://www.taxtmi.com/caselaws?id=276929 Section 23A was treated as a valid anti-avoidance machinery within the taxing power over income: undistributed profits of a controlled company remained the company's income, and the statutory fiction deeming a shareholder's notional share did not offend Articles 13, 14 or 19(1)(f). The classification of controlled companies and their shareholders was accepted as a reasonable and non-discriminatory basis, and the company-only appeal restriction was upheld. On reassessment, the notional shareholder income was treated as escaped assessment under section 34(1)(b), not section 34(1)(a), because it had not been brought to tax in the original assessment. Limitation was computed by reference to the assessment year, so the notices were within time. en-us Tue, 24 Apr 1956 00:00:00 +0530 Tue, 20 Nov 2018 15:11:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=276929 Section 23A was treated as a valid anti-avoidance machinery within the taxing power over income: undistributed profits of a controlled company remained the company's income, and the statutory fiction deeming a shareholder's notional share did not offend Articles 13, 14 or 19(1)(f). The classification of controlled companies and their shareholders was accepted as a reasonable and non-discriminatory basis, and the company-only appeal restriction was upheld. On reassessment, the notional shareholder income was treated as escaped assessment under section 34(1)(b), not section 34(1)(a), because it had not been brought to tax in the original assessment. Limitation was computed by reference to the assessment year, so the notices were within time. Case-Laws Income Tax Tue, 24 Apr 1956 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=276929