1921) 1 KB 64 and Federation of A.P. Chambers of Commerce and Industry and Ors. v. State of A.P. and Ors.

6 SCC 550Reported decision2000#1025 most cited

What is 1921) 1 KB 64 and Federation of A.P. Chambers of Commerce and Industry and Ors. v. State of A.P. and Ors. authority for?

The case holds that taxing statutes must be interpreted strictly based on their plain language. Courts should not read anything into the statute, imply intendment, or consider equity, hardship, or injustice.

106

judgments rely on this decision, according to BharatTax’s citation analysis of 366,339 Indian tax judgments — from 2010 to 2024.

Also referred to as

Federation of A.P. Chambers of Commerce · strict interpretation of taxing statutes · no equity about tax · literal rule of interpretation · plain language tax statutes · hardship injustice tax law · section 43B · section 36 · section 34 · section 40A(2)

Issues it is cited on

section 43(b)section 3(b)section 34(1)(iv)section 36(va)actual payment basissection 43b(b)section 34(1)section 36(1)(iv)section 40a(2)section 250ofsection 41section 34

Judgments citing 1921) 1 KB 64 and Federation of A.P. Chambers of Commerce and Industry and Ors. v. State of A.P. and Ors.

J P Associates, Korba vs. Ad. Commissioner of Income Tax (CPC), Bangalore

ITA 79/RPR/2021[2019-20]Status: DisposedITAT Raipur12 Jun 2023AY 2019-20

Bench: Shri Ravish Sood & Shri Arun Khodpia

For Appellant: Shri Abhishek Mahawar, CAFor Respondent: Shri V.K Singh, CIT-DR

…is to be implied. There is no room for any intendment. There is no equity about a tax. (See: Cape Brandy Syndicate v. Inland Revenue Commissioners (1921) 1 KB 64 and Federation of A.P. Chambers of Commerce and Industry and Ors. v. State of A.P. and Ors.(2000) 6 SCC 550. In interpreting a taxing statute, the Court must look squarely at the words of the statute and interpret them. Considerations of hardship, injustice and equity are entirely out of place in interpreting a taxing statute. (Also see: Commissioner of Sales Tax, Uttar Pradesh v. The Modi Sugar Mills Ltd. 1961 (2) SCR 189.)” 47. Likewise, this court und…

Shri Ram Finance Corporation Pvt. Ltd., Raipur vs. Dy. Commissioner of Income Tax, CPC, Bangalore

ITA 78/RPR/2021[2019-20]Status: DisposedITAT Raipur12 Jun 2023AY 2019-20

Bench: Shri Ravish Sood & Shri Arun Khodpia

For Appellant: Shri Abhishek Mahawar, CAFor Respondent: Shri V.K Singh, CIT-DR

…is to be implied. There is no room for any intendment. There is no equity about a tax. (See: Cape Brandy Syndicate v. Inland Revenue Commissioners (1921) 1 KB 64 and Federation of A.P. Chambers of Commerce and Industry and Ors. v. State of A.P. and Ors.(2000) 6 SCC 550. In interpreting a taxing statute, the Court must look squarely at the words of the statute and interpret them. Considerations of hardship, injustice and equity are entirely out of place in interpreting a taxing statute. (Also see: Commissioner of Sales Tax, Uttar Pradesh v. The Modi Sugar Mills Ltd. 1961 (2) SCR 189.)” 47. Likewise, this court und…

Shri Ram Finance Corporation Pvt. Ltd., Raipur vs. Dy. Commissioner of Income Tax, CPC, Bangalore

ITA 77/RPR/2021[2018-19]Status: DisposedITAT Raipur12 Jun 2023AY 2018-19

Bench: Shri Ravish Sood & Shri Arun Khodpia

For Appellant: Shri Abhishek Mahawar, CAFor Respondent: Shri V.K Singh, CIT-DR

…is to be implied. There is no room for any intendment. There is no equity about a tax. (See: Cape Brandy Syndicate v. Inland Revenue Commissioners (1921) 1 KB 64 and Federation of A.P. Chambers of Commerce and Industry and Ors. v. State of A.P. and Ors.(2000) 6 SCC 550. In interpreting a taxing statute, the Court must look squarely at the words of the statute and interpret them. Considerations of hardship, injustice and equity are entirely out of place in interpreting a taxing statute. (Also see: Commissioner of Sales Tax, Uttar Pradesh v. The Modi Sugar Mills Ltd. 1961 (2) SCR 189.)” 47. Likewise, this court und…

G R Minerals and Industries Pvt. Ltd., Raipur vs. Dy. Commissioner of Income Tax, CPC, Bangalore

ITA 76/RPR/2021[2018-19]Status: DisposedITAT Raipur12 Jun 2023AY 2018-19

Bench: Shri Ravish Sood & Shri Arun Khodpia

For Appellant: Shri Abhishek Mahawar, CAFor Respondent: Shri V.K Singh, CIT-DR

…is to be implied. There is no room for any intendment. There is no equity about a tax. (See: Cape Brandy Syndicate v. Inland Revenue Commissioners (1921) 1 KB 64 and Federation of A.P. Chambers of Commerce and Industry and Ors. v. State of A.P. and Ors.(2000) 6 SCC 550. In interpreting a taxing statute, the Court must look squarely at the words of the statute and interpret them. Considerations of hardship, injustice and equity are entirely out of place in interpreting a taxing statute. (Also see: Commissioner of Sales Tax, Uttar Pradesh v. The Modi Sugar Mills Ltd. 1961 (2) SCR 189.)” 47. Likewise, this court und…

Jharna Jaiswal, Raipur vs. CIT(A), NFAC, Delhi

ITA 74/RPR/2021[2018-19]Status: DisposedITAT Raipur12 Jun 2023AY 2018-19

Bench: Shri Ravish Sood & Shri Arun Khodpia

For Appellant: Shri Abhishek Mahawar, CAFor Respondent: Shri V.K Singh, CIT-DR

…is to be implied. There is no room for any intendment. There is no equity about a tax. (See: Cape Brandy Syndicate v. Inland Revenue Commissioners (1921) 1 KB 64 and Federation of A.P. Chambers of Commerce and Industry and Ors. v. State of A.P. and Ors.(2000) 6 SCC 550. In interpreting a taxing statute, the Court must look squarely at the words of the statute and interpret them. Considerations of hardship, injustice and equity are entirely out of place in interpreting a taxing statute. (Also see: Commissioner of Sales Tax, Uttar Pradesh v. The Modi Sugar Mills Ltd. 1961 (2) SCR 189.)” 47. Likewise, this court und…

Nanesh Projects, Raipur vs. Deputy Commissioner of Income Tax, CPC, Bangalore

ITA 64/RPR/2021[2019-20]Status: DisposedITAT Raipur12 Jun 2023AY 2019-20

Bench: Shri Ravish Sood & Shri Arun Khodpia

For Appellant: Shri Abhishek Mahawar, CAFor Respondent: Shri V.K Singh, CIT-DR

…is to be implied. There is no room for any intendment. There is no equity about a tax. (See: Cape Brandy Syndicate v. Inland Revenue Commissioners (1921) 1 KB 64 and Federation of A.P. Chambers of Commerce and Industry and Ors. v. State of A.P. and Ors.(2000) 6 SCC 550. In interpreting a taxing statute, the Court must look squarely at the words of the statute and interpret them. Considerations of hardship, injustice and equity are entirely out of place in interpreting a taxing statute. (Also see: Commissioner of Sales Tax, Uttar Pradesh v. The Modi Sugar Mills Ltd. 1961 (2) SCR 189.)” 47. Likewise, this court und…

M/S. Prentia Constructions, Jagdalpur vs. Income Tax Officer, Ward-Jagdalpur, Jagdalpur

ITA 62/RPR/2021[2019-20]Status: DisposedITAT Raipur12 Jun 2023AY 2019-20

Bench: Shri Ravish Sood & Shri Arun Khodpia

For Appellant: Shri Abhishek Mahawar, CAFor Respondent: Shri V.K Singh, CIT-DR

…is to be implied. There is no room for any intendment. There is no equity about a tax. (See: Cape Brandy Syndicate v. Inland Revenue Commissioners (1921) 1 KB 64 and Federation of A.P. Chambers of Commerce and Industry and Ors. v. State of A.P. and Ors.(2000) 6 SCC 550. In interpreting a taxing statute, the Court must look squarely at the words of the statute and interpret them. Considerations of hardship, injustice and equity are entirely out of place in interpreting a taxing statute. (Also see: Commissioner of Sales Tax, Uttar Pradesh v. The Modi Sugar Mills Ltd. 1961 (2) SCR 189.)” 47. Likewise, this court und…

M/S. Prenita Constructions, Jagdalpur vs. Dy. Commissioner of Income Tax, CPC, Bangalore

ITA 58/RPR/2021[2018-19]Status: DisposedITAT Raipur12 Jun 2023AY 2018-19

Bench: Shri Ravish Sood & Shri Arun Khodpia

For Appellant: Shri Abhishek Mahawar, CAFor Respondent: Shri V.K Singh, CIT-DR

…is to be implied. There is no room for any intendment. There is no equity about a tax. (See: Cape Brandy Syndicate v. Inland Revenue Commissioners (1921) 1 KB 64 and Federation of A.P. Chambers of Commerce and Industry and Ors. v. State of A.P. and Ors.(2000) 6 SCC 550. In interpreting a taxing statute, the Court must look squarely at the words of the statute and interpret them. Considerations of hardship, injustice and equity are entirely out of place in interpreting a taxing statute. (Also see: Commissioner of Sales Tax, Uttar Pradesh v. The Modi Sugar Mills Ltd. 1961 (2) SCR 189.)” 47. Likewise, this court und…

Sankalp Realities, Raipur vs. Dy. Commissioner of Income Tax (CPC), Bangalore

ITA 103/RPR/2021[2017-18]Status: DisposedITAT Raipur12 Jun 2023AY 2017-18

Bench: Shri Ravish Sood & Shri Arun Khodpia

For Appellant: Shri Abhishek Mahawar, CAFor Respondent: Shri V.K Singh, CIT-DR

…is to be implied. There is no room for any intendment. There is no equity about a tax. (See: Cape Brandy Syndicate v. Inland Revenue Commissioners (1921) 1 KB 64 and Federation of A.P. Chambers of Commerce and Industry and Ors. v. State of A.P. and Ors.(2000) 6 SCC 550. In interpreting a taxing statute, the Court must look squarely at the words of the statute and interpret them. Considerations of hardship, injustice and equity are entirely out of place in interpreting a taxing statute. (Also see: Commissioner of Sales Tax, Uttar Pradesh v. The Modi Sugar Mills Ltd. 1961 (2) SCR 189.)” 47. Likewise, this court und…

Kinger Agrico Private Limited, Raipur vs. Dy. Commissioner of Income Tax, CPC, Bangalore

ITA 102/RPR/2021[2018-19]Status: DisposedITAT Raipur12 Jun 2023AY 2018-19

Bench: Shri Ravish Sood & Shri Arun Khodpia

For Appellant: Shri Abhishek Mahawar, CAFor Respondent: Shri V.K Singh, CIT-DR

…is to be implied. There is no room for any intendment. There is no equity about a tax. (See: Cape Brandy Syndicate v. Inland Revenue Commissioners (1921) 1 KB 64 and Federation of A.P. Chambers of Commerce and Industry and Ors. v. State of A.P. and Ors.(2000) 6 SCC 550. In interpreting a taxing statute, the Court must look squarely at the words of the statute and interpret them. Considerations of hardship, injustice and equity are entirely out of place in interpreting a taxing statute. (Also see: Commissioner of Sales Tax, Uttar Pradesh v. The Modi Sugar Mills Ltd. 1961 (2) SCR 189.)” 47. Likewise, this court und…

N.R. Wires Private Limited, Bhilai vs. Deputy Commissioner of Income Tax, Circle 1(1), Bhilai

ITA 67/RPR/2019[2013-14]Status: DisposedITAT Raipur12 Jun 2023AY 2013-14

Bench: Shri Ravish Sood & Shri Arun Khodpia

For Appellant: Shri Abhishek Mahawar, CAFor Respondent: Shri V.K Singh, CIT-DR

…is to be implied. There is no room for any intendment. There is no equity about a tax. (See: Cape Brandy Syndicate v. Inland Revenue Commissioners (1921) 1 KB 64 and Federation of A.P. Chambers of Commerce and Industry and Ors. v. State of A.P. and Ors.(2000) 6 SCC 550. In interpreting a taxing statute, the Court must look squarely at the words of the statute and interpret them. Considerations of hardship, injustice and equity are entirely out of place in interpreting a taxing statute. (Also see: Commissioner of Sales Tax, Uttar Pradesh v. The Modi Sugar Mills Ltd. 1961 (2) SCR 189.)” 47. Likewise, this court und…

Mesers Vicon Motorcycle and Scooter India Private Limited, Raipur vs. Assisttant Commissioner of Income Tax, Circle -4(1), Raipur

ITA 194/RPR/2019[2015-16]Status: DisposedITAT Raipur12 Jun 2023AY 2015-16

Bench: Shri Ravish Sood & Shri Arun Khodpia

For Appellant: Shri Abhishek Mahawar, CAFor Respondent: Shri V.K Singh, CIT-DR

…is to be implied. There is no room for any intendment. There is no equity about a tax. (See: Cape Brandy Syndicate v. Inland Revenue Commissioners (1921) 1 KB 64 and Federation of A.P. Chambers of Commerce and Industry and Ors. v. State of A.P. and Ors.(2000) 6 SCC 550. In interpreting a taxing statute, the Court must look squarely at the words of the statute and interpret them. Considerations of hardship, injustice and equity are entirely out of place in interpreting a taxing statute. (Also see: Commissioner of Sales Tax, Uttar Pradesh v. The Modi Sugar Mills Ltd. 1961 (2) SCR 189.)” 47. Likewise, this court und…

Mesers Sky Automobiles, Raipur (Cg) vs. Deputy Commissioner of Income Tax, Circle - 2(1), Raipur (Cg)

ITA 149/RPR/2019[2013-14]Status: DisposedITAT Raipur12 Jun 2023AY 2013-14

Bench: Shri Ravish Sood & Shri Arun Khodpia

For Appellant: Shri Abhishek Mahawar, CAFor Respondent: Shri V.K Singh, CIT-DR

…is to be implied. There is no room for any intendment. There is no equity about a tax. (See: Cape Brandy Syndicate v. Inland Revenue Commissioners (1921) 1 KB 64 and Federation of A.P. Chambers of Commerce and Industry and Ors. v. State of A.P. and Ors.(2000) 6 SCC 550. In interpreting a taxing statute, the Court must look squarely at the words of the statute and interpret them. Considerations of hardship, injustice and equity are entirely out of place in interpreting a taxing statute. (Also see: Commissioner of Sales Tax, Uttar Pradesh v. The Modi Sugar Mills Ltd. 1961 (2) SCR 189.)” 47. Likewise, this court und…

Shri Shri Ranveer Singh Vidhuri, Raipur vs. The Dy. Commissioner of Income Tax, -2(1), Raipur (Cg)

ITA 304/BIL/2016[2012-13]Status: DisposedITAT Raipur12 Jun 2023AY 2012-13

Bench: Shri Ravish Sood & Shri Arun Khodpia

For Appellant: Shri Abhishek Mahawar, CAFor Respondent: Shri V.K Singh, CIT-DR

…is to be implied. There is no room for any intendment. There is no equity about a tax. (See: Cape Brandy Syndicate v. Inland Revenue Commissioners (1921) 1 KB 64 and Federation of A.P. Chambers of Commerce and Industry and Ors. v. State of A.P. and Ors.(2000) 6 SCC 550. In interpreting a taxing statute, the Court must look squarely at the words of the statute and interpret them. Considerations of hardship, injustice and equity are entirely out of place in interpreting a taxing statute. (Also see: Commissioner of Sales Tax, Uttar Pradesh v. The Modi Sugar Mills Ltd. 1961 (2) SCR 189.)” 47. Likewise, this court und…

Shri Shashikumar S Mishra, Bharuch vs. Assistant Commissioner of Income Tax, Circle -1, Bharuch

ITA 99/SRT/2023[2017-18]Status: DisposedITAT Surat31 May 2023AY 2017-18

Bench: Shripawan Singh, Jm &Dr. A.L.Saini, Am आयकरअपीलसं./Ita Nos.97 To101/Srt/2023 (िनधा"रणवष" / Assessment Years: (2015-16 To 2019-20) (Virtual Court Hearing) Shri Shashikumar S Mishra Asstt. Commissioner Of Income-Tax, Circle-I, Bharuch Ayakar Bhawan, A/7, Ashirwad Nagar Society, Station Road, Bharuch-392001 Bholav, Bharuch-392001 Vs. Enterprises.Nihal@Yahoo.Com Deputy Commissioner Of Income- Tax, Central Circle-2, Vadodara, Aykar Bhawan, Vadodara-39007 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aoqpm 4008 N (अपीलाथ" /Appellant ) (""थ"/Respondent)

For Appellant: Shri Bharat Jhaveri, AdvocateFor Respondent: Shri Vinod Kumar, Sr-DR
Section 143(3)Section 36(1)(va)Section 40Section 41Section 43Section 43B

…is to be implied. There is no room for any intendment. There is no equity about a tax. (See: Cape Brandy Syndicate v. Inland Revenue Commissioners (1921) 1 KB 64 and Federation of A.P. Chambers of Commerce and Industry and Ors. v. State of A.P. and Ors.(2000) 6 SCC 5 50. In interpreting a taxing statute, the Court must look squarely at the words of the statute and interpret them. Considerations of hardship, injustice and equity are entirely out of place in interpreting a taxing ITA Nos.97-101/SRT/2023 A.Ys.15-16 to 19-20 Sh Shashikumar S Mishra statute. (Also see: Commissioner of Sales Tax, Uttar Pradesh v. The…

Shri Shashikumar S Mishra, Bharuch vs. Assistant Commissioner of Income Tax, Circle -1, Bharuch

ITA 98/SRT/2023[2016-17]Status: DisposedITAT Surat31 May 2023AY 2016-17

Bench: Shripawan Singh, Jm &Dr. A.L.Saini, Am आयकरअपीलसं./Ita Nos.97 To101/Srt/2023 (िनधा"रणवष" / Assessment Years: (2015-16 To 2019-20) (Virtual Court Hearing) Shri Shashikumar S Mishra Asstt. Commissioner Of Income-Tax, Circle-I, Bharuch Ayakar Bhawan, A/7, Ashirwad Nagar Society, Station Road, Bharuch-392001 Bholav, Bharuch-392001 Vs. Enterprises.Nihal@Yahoo.Com Deputy Commissioner Of Income- Tax, Central Circle-2, Vadodara, Aykar Bhawan, Vadodara-39007 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aoqpm 4008 N (अपीलाथ" /Appellant ) (""थ"/Respondent)

For Appellant: Shri Bharat Jhaveri, AdvocateFor Respondent: Shri Vinod Kumar, Sr-DR
Section 143(3)Section 36(1)(va)Section 40Section 41Section 43Section 43B

…is to be implied. There is no room for any intendment. There is no equity about a tax. (See: Cape Brandy Syndicate v. Inland Revenue Commissioners (1921) 1 KB 64 and Federation of A.P. Chambers of Commerce and Industry and Ors. v. State of A.P. and Ors.(2000) 6 SCC 5 50. In interpreting a taxing statute, the Court must look squarely at the words of the statute and interpret them. Considerations of hardship, injustice and equity are entirely out of place in interpreting a taxing ITA Nos.97-101/SRT/2023 A.Ys.15-16 to 19-20 Sh Shashikumar S Mishra statute. (Also see: Commissioner of Sales Tax, Uttar Pradesh v. The…

Shri Shashikumar S Mishra, Bharuch vs. Assistant Commissioner of Income Tax, Circle -1, Bharuch

ITA 97/SRT/2023[2015-16]Status: DisposedITAT Surat31 May 2023AY 2015-16

Bench: Shripawan Singh, Jm &Dr. A.L.Saini, Am आयकरअपीलसं./Ita Nos.97 To101/Srt/2023 (िनधा"रणवष" / Assessment Years: (2015-16 To 2019-20) (Virtual Court Hearing) Shri Shashikumar S Mishra Asstt. Commissioner Of Income-Tax, Circle-I, Bharuch Ayakar Bhawan, A/7, Ashirwad Nagar Society, Station Road, Bharuch-392001 Bholav, Bharuch-392001 Vs. Enterprises.Nihal@Yahoo.Com Deputy Commissioner Of Income- Tax, Central Circle-2, Vadodara, Aykar Bhawan, Vadodara-39007 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aoqpm 4008 N (अपीलाथ" /Appellant ) (""थ"/Respondent)

For Appellant: Shri Bharat Jhaveri, AdvocateFor Respondent: Shri Vinod Kumar, Sr-DR
Section 143(3)Section 36(1)(va)Section 40Section 41Section 43Section 43B

…is to be implied. There is no room for any intendment. There is no equity about a tax. (See: Cape Brandy Syndicate v. Inland Revenue Commissioners (1921) 1 KB 64 and Federation of A.P. Chambers of Commerce and Industry and Ors. v. State of A.P. and Ors.(2000) 6 SCC 5 50. In interpreting a taxing statute, the Court must look squarely at the words of the statute and interpret them. Considerations of hardship, injustice and equity are entirely out of place in interpreting a taxing ITA Nos.97-101/SRT/2023 A.Ys.15-16 to 19-20 Sh Shashikumar S Mishra statute. (Also see: Commissioner of Sales Tax, Uttar Pradesh v. The…

Shri Shashikumar S Mishra, Bharuch vs. Assistant Commissioner of Income Tax, Circle -1, Bharuch

ITA 101/SRT/2023[2019-20]Status: DisposedITAT Surat31 May 2023AY 2019-20

Bench: Shripawan Singh, Jm &Dr. A.L.Saini, Am आयकरअपीलसं./Ita Nos.97 To101/Srt/2023 (िनधा"रणवष" / Assessment Years: (2015-16 To 2019-20) (Virtual Court Hearing) Shri Shashikumar S Mishra Asstt. Commissioner Of Income-Tax, Circle-I, Bharuch Ayakar Bhawan, A/7, Ashirwad Nagar Society, Station Road, Bharuch-392001 Bholav, Bharuch-392001 Vs. Enterprises.Nihal@Yahoo.Com Deputy Commissioner Of Income- Tax, Central Circle-2, Vadodara, Aykar Bhawan, Vadodara-39007 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aoqpm 4008 N (अपीलाथ" /Appellant ) (""थ"/Respondent)

For Appellant: Shri Bharat Jhaveri, AdvocateFor Respondent: Shri Vinod Kumar, Sr-DR
Section 143(3)Section 36(1)(va)Section 40Section 41Section 43Section 43B

…is to be implied. There is no room for any intendment. There is no equity about a tax. (See: Cape Brandy Syndicate v. Inland Revenue Commissioners (1921) 1 KB 64 and Federation of A.P. Chambers of Commerce and Industry and Ors. v. State of A.P. and Ors.(2000) 6 SCC 5 50. In interpreting a taxing statute, the Court must look squarely at the words of the statute and interpret them. Considerations of hardship, injustice and equity are entirely out of place in interpreting a taxing ITA Nos.97-101/SRT/2023 A.Ys.15-16 to 19-20 Sh Shashikumar S Mishra statute. (Also see: Commissioner of Sales Tax, Uttar Pradesh v. The…

Shri Shashikumar S Mishra, Bharuch vs. Assistant Commissioner of Income Tax, Circle -1, Bharuch

ITA 100/SRT/2023[2018-19]Status: DisposedITAT Surat31 May 2023AY 2018-19

Bench: Shripawan Singh, Jm &Dr. A.L.Saini, Am आयकरअपीलसं./Ita Nos.97 To101/Srt/2023 (िनधा"रणवष" / Assessment Years: (2015-16 To 2019-20) (Virtual Court Hearing) Shri Shashikumar S Mishra Asstt. Commissioner Of Income-Tax, Circle-I, Bharuch Ayakar Bhawan, A/7, Ashirwad Nagar Society, Station Road, Bharuch-392001 Bholav, Bharuch-392001 Vs. Enterprises.Nihal@Yahoo.Com Deputy Commissioner Of Income- Tax, Central Circle-2, Vadodara, Aykar Bhawan, Vadodara-39007 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aoqpm 4008 N (अपीलाथ" /Appellant ) (""थ"/Respondent)

For Appellant: Shri Bharat Jhaveri, AdvocateFor Respondent: Shri Vinod Kumar, Sr-DR
Section 143(3)Section 36(1)(va)Section 40Section 41Section 43Section 43B

…is to be implied. There is no room for any intendment. There is no equity about a tax. (See: Cape Brandy Syndicate v. Inland Revenue Commissioners (1921) 1 KB 64 and Federation of A.P. Chambers of Commerce and Industry and Ors. v. State of A.P. and Ors.(2000) 6 SCC 5 50. In interpreting a taxing statute, the Court must look squarely at the words of the statute and interpret them. Considerations of hardship, injustice and equity are entirely out of place in interpreting a taxing ITA Nos.97-101/SRT/2023 A.Ys.15-16 to 19-20 Sh Shashikumar S Mishra statute. (Also see: Commissioner of Sales Tax, Uttar Pradesh v. The…

Shivendra Singh, Raipur vs. Assessing Officer, Ward-3(1), Raipur

ITA 13/RPR/2022[2019-20]Status: DisposedITAT Raipur30 May 2023AY 2019-20

Bench: Shri Ravish Sood

For Appellant: Shri Nilesh Jain, CAFor Respondent: Shri Piyush Tripathi, Sr. DR
Section 36(1)(va)

…is to be implied. There is no room for any intendment. There is no equity about a tax. (See: Cape Brandy Syndicate v. Inland Revenue Commissioners (1921) 1 KB 64 and Federation of A.P. Chambers of Commerce and Industry and Ors. v. State of A.P. and Ors.(2000) 6 SCC 550. In interpreting a taxing statute, the Court must look squarely at the words of the statute and interpret them. Considerations of hardship, injustice and equity are entirely out of place in interpreting a taxing statute. (Also see: Commissioner of Sales Tax, Uttar Pradesh v. The Modi Sugar Mills Ltd. 1961 (2) SCR 189.)” 47. Likewise, this court und…