https://www.taxtmi.com/caselaws?id=49492 Paragraph 12 of the Merged States (Taxation Concessions) Order, 1949 confines protection to the specific previous year ending before 1 August 1949 and therefore shields only profits and gains earned in the merged State for that previous year; it does not bar application of section 23A to the company's assessable income arising in British India, which remains subject to the statutory fiction of deemed distribution. Interest under section 18A(8) is not income-tax or super-tax and therefore is not deductible when computing amounts deemed distributed under section 23A. Deemed distributions from taxable-territory income are taxable in shareholders' hands. en-us Thu, 12 Jan 1961 00:00:00 +0530 Sat, 30 Aug 2014 21:38:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=49492 Paragraph 12 of the Merged States (Taxation Concessions) Order, 1949 confines protection to the specific previous year ending before 1 August 1949 and therefore shields only profits and gains earned in the merged State for that previous year; it does not bar application of section 23A to the company's assessable income arising in British India, which remains subject to the statutory fiction of deemed distribution. Interest under section 18A(8) is not income-tax or super-tax and therefore is not deductible when computing amounts deemed distributed under section 23A. Deemed distributions from taxable-territory income are taxable in shareholders' hands. Case-Laws Income Tax Thu, 12 Jan 1961 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=49492