Parshavnath Associates, Kota vs. ACIT/DCIT, Central Circle, Kota
In the result, both the appeal filed by separate assessee are allowed in terms of the above observations
ITA 1358/JPR/2024[2018-19]Status: DisposedITAT Jaipur19 Mar 2025AY 2018-19
Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)
For Appellant: Shri Mahendra Gargieya, Adv.&For Respondent: Smt. Runi Pal, CIT a
Section 133ASection 139Section 143(3)Section 234ASection 244ASection 69C
…rued like any other statute. The machinery provisions must, no doubt, be so construed as would effectuate the object and purpose of the statute and not defeat the same. (Whitney v. Commissioners of Inland Revenue 1926 A C. 37, CIT v. Mahaliram Ramjidas [1940] 8 ITR 42 (PC), Indian United Mills Ltd. v. Commissioner of Excess Profits Tax, Bombay, [1995] 27 ITR 20 (SC) and Gursahai Saigal v. CIT, Punjab, [1963] 48 ITR 1 (SC)." The Hon'ble Supreme Court in the case of Gursahal Saigal (supra) held as under: "Those sections which impose the charge or levy should be strictly construed, but those which deal merely with t…