https://www.taxtmi.com/caselaws?id=49376 The Supreme Court dismissed the appeals and upheld the High Court's order, concluding that the Explanation to Section 23A did not apply as there was no presumption based on the facts found. The court emphasized the importance of investigating controlling interest in determining if a company is substantially interested by the public. As the revenue authorities failed to establish the existence of a controlling interest by a group of shareholders, the appeals were dismissed with costs. en-us Tue, 28 Apr 1964 00:00:00 +0530 Sat, 23 Aug 2014 11:43:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=49376 The Supreme Court dismissed the appeals and upheld the High Court's order, concluding that the Explanation to Section 23A did not apply as there was no presumption based on the facts found. The court emphasized the importance of investigating controlling interest in determining if a company is substantially interested by the public. As the revenue authorities failed to establish the existence of a controlling interest by a group of shareholders, the appeals were dismissed with costs. Case-Laws Income Tax Tue, 28 Apr 1964 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=49376