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1984 (9) TMI 24
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....on referred to us by the Income-tax Appellate Tribunal is as under " Whether shares held by a company in which the public are substantially interested within the meaning of section 2(18) of the Income-tax Act, 1961, are shares held by the public within the meaning of section 2(18)(b) ? " Thus, in the orders of the Income-tax Officer, Appellate Assistant Commissioner and the Tribunal from whi....
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.... has been referred to the High Court and the answer to be given to that question would seem to depend only on the applicability of the first of the three conditions. The learned advocate for the assessee has drawn our attention to decision of the Division Bench of this Court (to which I was a party), in which decision this point has been considered and where the answer has been given in favour ....
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....ch fact is referred to in the statement of the case, that the auditors of Rank Organisation Ltd. had certified this by their letter dated July 7, 1964, the relevant portion of which is mentioned in paragraph I of the statement of the case. The learned advocate for the assessee company has drawn our attention to the case of CIT v. Baroda Investment Co. Ltd. [1979] 119 ITR 14 (Bom), in which it h....