https://www.taxtmi.com/caselaws?id=49630 A statutory deeming provision that treated failure to send an estimate under section 18A(3) as failure to furnish a return of total income also attracted the penalty machinery under section 28. The court reasoned that the deeming fiction must be given full effect, including the statutory notice framework necessary for the substituted default to operate, so the conditions for penalty were satisfied. A narrow construction that excluded penalty would have deprived section 18A(9)(b) of practical effect and undermined its legislative purpose. Strict construction of fiscal statutes did not displace the clear language and object of the provision. en-us Wed, 05 Nov 1958 00:00:00 +0530 Fri, 05 Sep 2014 09:56:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=49630 A statutory deeming provision that treated failure to send an estimate under section 18A(3) as failure to furnish a return of total income also attracted the penalty machinery under section 28. The court reasoned that the deeming fiction must be given full effect, including the statutory notice framework necessary for the substituted default to operate, so the conditions for penalty were satisfied. A narrow construction that excluded penalty would have deprived section 18A(9)(b) of practical effect and undermined its legislative purpose. Strict construction of fiscal statutes did not displace the clear language and object of the provision. Case-Laws Income Tax Wed, 05 Nov 1958 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=49630