“Section 252(3)”
The decision most relied on for Section 252(3) is CIT v. Anjum M.H. Ghaswala (252 ITR 1), cited in 452 judgments on BharatTax.
Leading authorities on Section 252(3)
Levy of interest under sections 234A, 234B, and 234C of the Income Tax Act is mandatory. Tax statutes are to be interpreted strictly, allowing no room for purposive interpretation.
The Assessing Officer must grant the correct deduction after due verification of claims made by the assessee, even if not perfectly articulated initially. This principle applies in assessment proceedings, including those involving specific deductions like those for export-oriented units under Section 10B.
Rectification under Section 154 is permissible based on a subsequent judgment of the Jurisdictional High Court or the Supreme Court. Such a judgment clarifies the law as it always stood, thereby revealing a mistake apparent from the record.
Seized material obtained during a search operation must be read in its entirety, and the 'pick and choose' theory cannot be adopted when interpreting such material.
An assessee cannot be penalized for the actions of its supplier, nor can it be expected to know the commercial rationale behind how a supplier operates its bank account. The assessee is not burdened with the task of investigating the genuineness of the seller or their business transactions if they have provided evidence like bank statements and purchase bills to prove the genuineness of their own purchases and the Assessing Officer has not doubted their sales.