Case Law Details
Case Name : Bee Pee Jay Finance Ltd. Vs Commissioner of Income Tax, Central- II & Anr. (Calcutta High Court)
Related Assessment Year :
Courts :
All High Courts Calcutta High Court
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Bee Pee Jay Finance Ltd. Vs CIT and Anr (Calcutta High Court)- By virtue of Section 11 5JA a legal fiction has been created by which if total income is found to be less than 30% of the book profit, the total income should be deemed to be 30% of the profit and in such a case, if charge ability of interest under Sections 234B and 234C are held applicable only in view of sub-Section (4) of Section 11 5JA, it would amount to adding another legal fiction to an existing legal fiction of Section 11 5JA( 1). According to Mr. Sen in case of a legal fiction, which has to be interpreted for giving its fu...
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when an assesses liable for interest u/s 234A, 234B,234C both