GURSAHAI SAIGAL vs COMMISSIONER OF INCOME-TAX, PUNJAB

The Supreme Court interpreted Section 18A of the Indian Income-tax Act, 1922, specifically subsections (2), (3), (6), (8), and (9), regarding the imposition of interest on unpaid taxes. The Court held that the provisions for calculating interest under subsection (6) should be applied even when no tax was paid, thereby imposing a liability to pay interest from January 1 of the financial year in which the tax was due. The ruling clarified that the machinery for assessment must be construed to fulfill the legislative intent of effective tax collection.