https://www.taxtmi.com/caselaws?id=276950 Section 23A of the Indian Income-tax Act, 1922 is described as constitutionally valid, and the limitation period in section 34 is said not to govern the initiation of proceedings under section 23A because no such limitation is prescribed for that stage. On the substantive application of section 23A, control is analysed by reference to voting power and real distribution of control, not merely formal shareholding labels. The commentary states that the public interest test depends on whether any person holds more than 50 per cent of voting power, or whether the public holds at least 25 per cent. On the stated facts, section 23A was wrongly applied and the action under it was annulled. en-us Tue, 05 Apr 1960 00:00:00 +0530 Tue, 20 Nov 2018 17:44:51 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=276950 Section 23A of the Indian Income-tax Act, 1922 is described as constitutionally valid, and the limitation period in section 34 is said not to govern the initiation of proceedings under section 23A because no such limitation is prescribed for that stage. On the substantive application of section 23A, control is analysed by reference to voting power and real distribution of control, not merely formal shareholding labels. The commentary states that the public interest test depends on whether any person holds more than 50 per cent of voting power, or whether the public holds at least 25 per cent. On the stated facts, section 23A was wrongly applied and the action under it was annulled. Case-Laws Income Tax Tue, 05 Apr 1960 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=276950