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Case lawCirculars1973 › Circular No. 101
CBDT circular 24 January 1973

Circular No. 101

12. Whether public company will be deemed to be company in which public are not substantially interested by reason only of the fact that number of its directors at any time during previous year is less than six

What this is

Circular No. 101 was issued by the Central Board of Direct Taxes on 24 January 1973. Its subject is 12. Whether public company will be deemed to be company in which public are not substantially interested by reason only of the fact that number of its directors at any time during previous year is less than six.

This is a clarification. The Board is stating how it reads a provision. That reading binds the department; it does not bind a court, and where the section says otherwise the section wins.

What it does

Directs Income-tax Officers to follow the 1955 instruction of the Central Board of Revenue when applying section 2(18)(b)(B)(iii) as it then stood, and encloses it. That instruction answers whether a public company is to be deemed one in which the public are not substantially interested merely because it had fewer than six directors at some time during the previous year. It says such a case is considered under the paragraph dealing with control of the affairs of the company, that no cut and dried definition of control of the affairs of a company is possible, and that control is not the same as a director running the business from day to day. It follows that there need not be at least six directors for the company to stay outside the provision.

Why it was issued

The question had been raised under the corresponding Explanation to section 23A of the 1922 Act, inserted by the Finance Act, 1955, and the Board carried the answer forward to the equivalent provision of the 1961 Act.

Who it reaches

The provisions it speaks to

Left, the provision of the Income-tax Act, 1961 as the instrument itself names it. Right, the section of the Income-tax Act, 2025 that the department’s own concordance maps it to — which is where the same ground is now covered.
Under the 1961 ActNow
s.2s.2, s.346, s.355
s.23Ano counterpart recorded

The instrument, as the Board published it

The words below are the department’s own, reproduced from its published text. Where the department’s copy carried a publisher’s notes after the instrument, those are not reproduced.

12. Whether public company will be deemed to be company in which public are not substantially interested by reason only of the fact that number of its directors at any time during previous year is less than six
1. Reference is invited to Circular No. 44 (LXXV-8) of 1955 [F. No. 4(47)55/Tec.], dated 1-11-1955 of the then Central Board of Revenue on the above subject copy of which is enclosed for ready reference [Annex].
2. Necessary instructions may please be issued to the Income-tax Officers to follow the instructions for purposes of section 2(18)(b)(B)(iii) [as it stood prior to its substitution by the Finance Act, 1983, w.e.f. 2-4-1983].
Circular: No. 101 [F. No. 195/1/72-IT(A-I)], dated 24-1-1973.
ANNEX - CIRCULAR, DATED 1-11-1955 REFERRED TO IN CLARIFICATION
A question has been raised whether the public company will be deemed to be a company in which the public are not substantially interested within the meaning of the Explanation to section 23A of the 1922 Act (inserted by the Finance Act, 1955) by reason only of the fact that the number of its directors at any time during the previous year is less than six. The case of such a company has to be considered under paragraph (iii) of the Explanation. It is not possible to give a cut and dried definition of the expression "control of the affairs of a company". It is, however, not the same as the running of the business from day-to-day by a director. It is, therefore, not necessary that there should be not less than six directors in order that section 23A should not apply.

What to watch

Where you meet it

An old dispute over whether a company was one in which the public are substantially interested, with consequences for the rate of tax and for provisions applying only to closely held companies.

On the same provision

Other instruments in this library that name the same provision of the 1961 Act. They are not necessarily still operative, and a later one may have replaced an earlier one without saying so.

← Circular No. 100  ·  Circular No. 99 →

A circular binds the department, not you and not a court. The Board issues a circular to its own officers. An assessee may hold the department to a circular that helps him; the department cannot hold an assessee to one that hurts him, and the Tribunal and the courts decide the law for themselves.

Source: the Income Tax Department’s own published text — its page for this instrument.