https://www.taxtmi.com/caselaws?id=28070 Section 271(2) deems a registered firm to be an unregistered firm for penalty purposes, so the penalty base must be computed on the tax payable on that footing. Because an unregistered firm was liable to annuity deposit and section 280-O then allowed that deposit to be deducted in computing total income, the same deduction had to be reflected in determining the tax base for penalty under section 271(1)(c). The legal fiction was applied to its full consequence, and the deduction of annuity deposit was treated as necessary in computing the penalty. en-us Fri, 03 Feb 1984 00:00:00 +0530 Wed, 17 Feb 2010 18:01:43 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=28070 Section 271(2) deems a registered firm to be an unregistered firm for penalty purposes, so the penalty base must be computed on the tax payable on that footing. Because an unregistered firm was liable to annuity deposit and section 280-O then allowed that deposit to be deducted in computing total income, the same deduction had to be reflected in determining the tax base for penalty under section 271(1)(c). The legal fiction was applied to its full consequence, and the deduction of annuity deposit was treated as necessary in computing the penalty. Case-Laws Income Tax Fri, 03 Feb 1984 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=28070