https://www.taxtmi.com/caselaws?id=290592 Proceedings before an income tax officer under Section 23(2) of the Income-tax Act, 1922 were not judicial proceedings for sustaining a conviction under Section 196 of the Indian Penal Code. Section 37 of the 1922 Act deems such proceedings to be judicial proceedings only for the limited purposes of Sections 193 and 228 of the Penal Code, and the deeming fiction, being penal in character, must be strictly construed. Because Section 196 was not expressly mentioned, the fiction could not be extended to that offence, and the conviction and sentence under Section 196 were set aside. en-us Wed, 15 Jun 1927 00:00:00 +0530 Tue, 06 Oct 2020 14:19:45 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=290592 Proceedings before an income tax officer under Section 23(2) of the Income-tax Act, 1922 were not judicial proceedings for sustaining a conviction under Section 196 of the Indian Penal Code. Section 37 of the 1922 Act deems such proceedings to be judicial proceedings only for the limited purposes of Sections 193 and 228 of the Penal Code, and the deeming fiction, being penal in character, must be strictly construed. Because Section 196 was not expressly mentioned, the fiction could not be extended to that offence, and the conviction and sentence under Section 196 were set aside. Case-Laws Income Tax Wed, 15 Jun 1927 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=290592