RAGHUVANSHI MILLS, LTD. vs COMMISSIONER OF INCOME-TAX, BOMBAY

The Supreme Court held that under Section 23A of the Indian Income-tax Act, 1922, the term 'public' refers to shareholders who do not act in unison and whose voting power does not constitute a block. The Court found that shares held by Directors and their relatives could not be considered as held by the public if they collectively control more than 75% of the voting power. The appeal by the assessee company was dismissed, affirming that the shares held by the Directors' family were not 'unconditionally' or 'beneficially' held by the public.