https://www.taxtmi.com/caselaws?id=36814 Section 271(2) deems a registered firm to be an unregistered firm for penalty computation, and that legal fiction must be applied fully when fixing the tax base. The Madras High Court's reasoning was that the provisions applicable to unregistered firms, including the annuity deposit rules, govern the computation, and section 280-O did not require actual payment of the deposit for deduction; it was enough that the deposit was one required by law. The later amendment did not change this position for penalty purposes, so the annuity deposit was deductible in calculating the penalty. en-us Tue, 18 Dec 1979 00:00:00 +0530 Sun, 22 Dec 2024 07:54:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=36814 Section 271(2) deems a registered firm to be an unregistered firm for penalty computation, and that legal fiction must be applied fully when fixing the tax base. The Madras High Court's reasoning was that the provisions applicable to unregistered firms, including the annuity deposit rules, govern the computation, and section 280-O did not require actual payment of the deposit for deduction; it was enough that the deposit was one required by law. The later amendment did not change this position for penalty purposes, so the annuity deposit was deductible in calculating the penalty. Case-Laws Income Tax Tue, 18 Dec 1979 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=36814