https://www.taxtmi.com/caselaws?id=38101 For penalty computation under section 271(1)(a), a registered firm deemed to be an unregistered firm under section 271(2) had to be assessed on the tax payable in that assumed character, and the statutory fiction carried all necessary incidents of that status. The Karnataka HC noted that the annuity deposit under Chapter 22A was allowable as a deduction in computing total income, and the law then in force did not require actual payment of the deposit as a condition for the deduction. The assessee was therefore entitled to that deduction when determining the tax base for penalty purposes, and the Commissioner's contrary view was erroneous. en-us Fri, 31 Mar 1978 00:00:00 +0530 Sat, 03 Apr 2010 12:04:33 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=38101 For penalty computation under section 271(1)(a), a registered firm deemed to be an unregistered firm under section 271(2) had to be assessed on the tax payable in that assumed character, and the statutory fiction carried all necessary incidents of that status. The Karnataka HC noted that the annuity deposit under Chapter 22A was allowable as a deduction in computing total income, and the law then in force did not require actual payment of the deposit as a condition for the deduction. The assessee was therefore entitled to that deduction when determining the tax base for penalty purposes, and the Commissioner's contrary view was erroneous. Case-Laws Income Tax Fri, 31 Mar 1978 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=38101