COMMISSIONER OF INCOME-TAX, MADRAS vs THE AMRUTANJAN LTD., MADRAS

The Supreme Court held that the respondent company was one in which the public were substantially interested, thus the Income-tax Officer lacked jurisdiction to issue an order under Section 23-A of the Indian Income Tax Act, 1922. The Court clarified that a company is deemed to have substantial public interest when more than half of the voting power is held by the public, and that controlling interests held by individuals or groups negate this status. The High Court's ruling was upheld, confirming the application of Section 23-A was incorrect for the years in question.