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    <title>1961 (1) TMI 10 - Supreme Court</title>
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    <description>Section 23A of the Income-tax Act, 1922 applied to the company&#039;s British Indian assessable income, because paragraph 12 of the Merged States (Taxation Concessions) Order, 1949 was confined to the protected Bhor State income for the specified previous year and did not exempt income already within the taxable territory. Interest charged under section 18A(8) was not deductible in computing the amount available for distribution, as it remained interest and was not treated as income-tax or super-tax. Deemed dividends under section 23A were also not exempt under section 14(2)(c), because the statutory fiction treated them as dividends received by shareholders and the exemption did not extend to such British Indian income.</description>
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    <pubDate>Thu, 12 Jan 1961 00:00:00 +0530</pubDate>
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      <title>1961 (1) TMI 10 - Supreme Court</title>
      <link>https://www.taxtmi.com/caselaws?id=49492</link>
      <description>Section 23A of the Income-tax Act, 1922 applied to the company&#039;s British Indian assessable income, because paragraph 12 of the Merged States (Taxation Concessions) Order, 1949 was confined to the protected Bhor State income for the specified previous year and did not exempt income already within the taxable territory. Interest charged under section 18A(8) was not deductible in computing the amount available for distribution, as it remained interest and was not treated as income-tax or super-tax. Deemed dividends under section 23A were also not exempt under section 14(2)(c), because the statutory fiction treated them as dividends received by shareholders and the exemption did not extend to such British Indian income.</description>
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      <pubDate>Thu, 12 Jan 1961 00:00:00 +0530</pubDate>
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