Karnataka Ssidc Ltd vs Commissioner Of Income Tax, Bangalore

The Supreme Court addressed the applicability of Section 115J(1) of the Income Tax Act, 1961, which mandates that companies pay tax on 30% of their book profits if their total income is less. The Court upheld the Income Tax Appellate Tribunal's ruling that depreciation deemed to be allowed under this section must be considered for calculating the written down value of assets in subsequent assessment years. The judgment clarified that the deemed income under Section 115J(1) does not negate the actual allowances permissible under other provisions of the Act, thereby affirming the Tribunal's interpretation of the tax scheme as an artificial overlay on regular income determination.