LAWS(BOM)-1946-9-21

CAMBATTA S C Vs. COMMISSIONER OF INCOME TAX

Decided On September 06, 1946
S.C. CAMBATTA Appellant
V/S
COMMISSIONER OF INCOME-TAX Respondents

JUDGEMENT

(1.) THIS is a reference under Section 66 (1) of the Indian Income-tax Act, 1922, and the questions, which under order of this Court of March 29, 1945, have been submitted by the Tribunal, are these:

(2.) SECTION 23A creates what might be described as an artificial income. It is as follows:-

(3.) SECTION 21 of the Indian Companies Act, 1913, is the section which makes the memorandum and articles of association of a company the contract between the company and its shareholders and it is as follows:-