https://www.taxtmi.com/caselaws?id=28688 Section 271(2) applies a statutory fiction that a registered firm is to be treated as an unregistered firm for penalty computation, and that fiction must be carried through to the normal tax consequences of that status. The tax base therefore includes the deduction that would have been available to an unregistered firm for annuity deposit under section 280-O, even if the registered firm did not actually make such a payment. The analysis treats the assumed status and its statutory incidents as inseparable for computing penalty, and supports deduction of the notional annuity deposit in the penalty base. en-us Wed, 28 Apr 1982 00:00:00 +0530 Wed, 24 Feb 2010 17:43:44 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=28688 Section 271(2) applies a statutory fiction that a registered firm is to be treated as an unregistered firm for penalty computation, and that fiction must be carried through to the normal tax consequences of that status. The tax base therefore includes the deduction that would have been available to an unregistered firm for annuity deposit under section 280-O, even if the registered firm did not actually make such a payment. The analysis treats the assumed status and its statutory incidents as inseparable for computing penalty, and supports deduction of the notional annuity deposit in the penalty base. Case-Laws Income Tax Wed, 28 Apr 1982 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=28688