Sysmex India Private Limited, Mumbai vs. Dy. C.I.T. 15(3)(2), Mumbai
In the result, appeal of the assessee is allowed
ITA 4454/MUM/2024[2017-2018]Status: DisposedITAT Mumbai09 Jan 2025AY 2017-2018
Bench: Sunil Kumar Singh, Hon’Ble
For Appellant: Shri Deepak Tikekar, C.A. & Shri Ashish Thakurdesai, C.A., A/RsFor Respondent: Shri Bhangepatil Pushkaraj Ramesh, Sr. D/R
Section 234BSection 234CSection 234DSection 244ASection 80
…of a statute is clear and explicit, effect must be given to each word. The Hon’ble Apex court has time and again reinforced this rule of interpretation of statutes in its judgements, right from Padmasundara Rao vs State of TN 255 ITR 147(SC), Mohammad Vs CWT 224 ITR 672(SC) & Pandian Chemicals Ltd. vs CIT 262 ITR 278(SC).In view of the same since the words used in section 80IC categorically state that the provisions of sub section 5 to section 80IA shall apply to the eligible undertaking or enterprise, they have to be read as such and applied to each undertaking, meaning thereby that the profits of each eligible…