Asst CIT Cir 4(3)(2), Mumbai vs. Morgan Stanley India Co.P.Ltd, Mumbai
ITA 1794/MUM/2016[2011-12]Status: DisposedITAT Mumbai15 Dec 2022AY 2011-12
Bench: Shri Prashant Maharishi, Am & Shri Pavan Kumar Gadale, Jm Co No. 145/Mum/2016 (Arising In Ita No. 1794/Mum/2016 For A.Y. 11-12)
For Appellant: Shri Sunil M. Lala, ARFor Respondent: Shri Samuel Pitta, DR
Section 143(3)Section 144CSection 14ASection 253Section 80G
…d principle of construction to brush aside words in a statute as being in apposite surplusage, if they can have appropriate application in circumstances conceivably within the contemplation of the statute." 037. In Phool Patti v. Ram Singh reported in (2009) 13 SCC 22, the Hon'ble Supreme Court held that, "9. It is a well-settled principle of interpretation that the court cannot add words to the statute or change its language, particularly when on a plain reading the meaning seems to be clear." 038. It is also to be noted that in none of the decisions cited by the LD AR, [including the decisions in case of the…