relied upon English decisions based on this Section in interpreting Section 3 (2) and Section 33(2) of the Indian ... British India. In other words,, the charging Section ( Section 3 ) was enlarged by the provisions of Section 33 (2) . On the other hand
British India. In other words, the charging section (Section 5) was enlarged by the provisions of Section 33 (1). On the other hand ... machinery" section. The question is whether the first part of the section is also a machinery section or a charging section. As' already
British India. In other words, the charging section (Section 5) was enlarged by the provisions of Section 33 (1). On the other hand ... extending the operations of Section 41 of the Income Tax Act 1842. That section is not a charging section and only relates to the method
Sections 3 and 4 of the Income-tax Act which are the charging sections. Section 22 and other connected sections are machinery sections to determine ... Clause (a) of Sub-section (1) thereof or under Section 23 to which Clause (c) of Sub-section (I) of Section 28 applies, shall
levy would fail as there will be no appropriate charging section or machinery for effectuating the levy on the activity like the method of processing ... justified under Entry 97 of List 1 of Seventh Schedule. The charging section is Section
machinery provision contained in sub-section (2) of section 12B of the 1922 Act or section 48 of the 1961 Act, in order to come ... machinery provision which is contained in sub-section (2) of section 12B of the 1922 Act, and section
Section 34 of the Indian Income-tax Act, 1922, and similarly, Section 148 of the Income-tax Act, 1961, are not charging sections but machinery ... learned judge further observed that Section 34 was not a charging section. It merely provided a machinery whereby an income which had escaped assessment
follows :
"It must be remembered that Section 25A is a machinery section. It is not a charging section, much less can it be construed ... Indian Income-tax Act, 1922, then it is only a machinery section and not a charging section. In that case Section 20 of the Wealth
connection with Section 18A, the Supreme Court observed that the provisions of this section laid down the machinery for the assessment of interest. That ... calculated in a certain manner and in giving effect to the machinery section, the Supreme Court noted, that the machinery section should be so construed
amalgamation or
succession, referred to in sub-section (6) or sub-section (7)."
Section 155(4A): "Where an allowance by way of investment ... same
meanings as in the Explanation below sub-section(2) of section
32A."
Section 2(47) : "transfer", in relation to a capital
