https://www.taxtmi.com/caselaws?id=23585 Section 17(1) of the Estate Duty Act, 1953 deems the assets of a controlled company to pass on death only to the extent computed under section 17(2). Proviso (a) to section 17(2) merely regulates how aggregate net income is calculated where one or more accounting years show a loss; it does not expand the charge to include the company's entire assets when the statutory fraction cannot be worked out. Where the aggregate net income produces a loss and the deemed proportion becomes negative, no deemed passing arises and the company's assets are excluded from the principal value of the estate. en-us Mon, 17 Apr 1989 00:00:00 +0530 Tue, 22 Dec 2009 13:15:45 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=23585 Section 17(1) of the Estate Duty Act, 1953 deems the assets of a controlled company to pass on death only to the extent computed under section 17(2). Proviso (a) to section 17(2) merely regulates how aggregate net income is calculated where one or more accounting years show a loss; it does not expand the charge to include the company's entire assets when the statutory fraction cannot be worked out. Where the aggregate net income produces a loss and the deemed proportion becomes negative, no deemed passing arises and the company's assets are excluded from the principal value of the estate. Case-Laws Income Tax Mon, 17 Apr 1989 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=23585