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“purposive interpretation”

MiscellaneousStatutory InterpretationStatutory Interpretation204 judgments

The decision most relied on for purposive interpretation is CIT v. Anjum M.H. Ghaswala (252 ITR 1), cited in 452 judgments on BharatTax.

Leading authorities on purposive interpretation

CIT v. Anjum M.H. Ghaswala
252 ITR 1 · 2001 · Supreme Court
452
citing judgments

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.

Bajaj Tempo Ltd. v. CIT
196 ITR 188 · 1992 · Supreme Court
289
citing judgments

Provisions in taxing statutes that grant incentives, concessions, or exemptions for promoting economic growth and industrialization must be interpreted liberally and purposively. Any restrictions placed on such provisions should also be construed reasonably to advance their objective, not frustrate it.

Concord of India Insurance Co. Ltd. v. Smt. Nirmala Devi and Others
118 ITR 507 · 1979 · Supreme Court
268
citing judgments

For condoning delay, the term 'sufficient cause' must be interpreted liberally and purposively to advance justice. Delay not tainted by mala fides, gross negligence, or recklessness, and based on honestly obtained legal advice, constitutes sufficient cause.

CIT v. Gold Coin Health Food Pvt. Ltd.
304 ITR 308 · 2008 · Supreme Court
229
citing judgments

A clarificatory or declaratory amendment to a statutory provision has retrospective effect from the date the original provision came into force, as its purpose is to clarify existing law rather than introduce new law.

Smt. Tarulata Shyam v. CIT
108 ITR 345 · 1977 · Supreme Court
209
citing judgments

Taxing statutes must be interpreted strictly, assuming that the law-making authority does not commit a mistake or make an omission. There is no room for purposive interpretation under direct tax laws.

Sreenivas Charitable Trust v. Dy. CIT
280 ITR 357 · 2006 · High Court
182
citing judgments

The expression "sufficient cause" for condoning delay in filing appeals must receive a liberal and purposive construction. This approach aims to advance substantial justice, which is of paramount importance.

CIT v. J.H. Gotla
156 ITR 323 · 1985 · Supreme Court
176
citing judgments

The Supreme Court holds that for income tax purposes, the term 'income' includes 'loss,' allowing for the set-off of a spouse's or minor child's business losses when their income is clubbed with the assessee. This decision emphasizes interpreting tax statutes, especially benevolent provisions, by considering the legislative scheme over a strict literal construction.

(ii) CIT v. Hindustan Bulk Carriers
3 SCC 57 · 2003 · Reported
131
citing judgments

Courts must reject interpretations that defeat the plain intention of the legislature, even if language is imprecise. A statute must be read as a whole, construing provisions harmoniously to avoid rendering any part otiose or a dead letter.

Judgments citing purposive interpretation

Amplus Energy Solutions Pte Ltd, Singapore vs. The Office of the Assistant Commissioner of Income Tax, New Delhi

ITA 2417/DEL/2023[2020-21]Status: DisposedITAT Delhi25 Jun 2025AY 2020-21

Bench: Shri Anubhav Sharma & Shri Manish Agarwalassessment Year: 2020-21 Amplus Energy Solutions Pte Vs Acit, Ltd., Circle International Tax 1(1)(1), #02-00, Robinson Road, New Delhi. Singapore – 688898 Pan: Aadci8182P Assessment Year: 2021-22 Amplus Energy Solutions Pte Vs. Acit, Ltd., Malaysia, Circle International Tax 1(1)(1), Level 56, Tower-1, Petronas New Delhi. Twin Towers, Kuala Lumpur City Centre, 50088, Kuala Lumpur, Malaysia/ 6Th Floor, Emaar Mgf, The Palm Square, Golf Course Ext. Road, Sector-66, Gurgaon – 122 102. Pan: Aadci8182P (Appellant) (Respondent) Assessee By : Shri K.M. Gupta, Advocate & Ms Shruti Khimta, Ar Revenue By : Ms Ekta Jain, Cit-Dr Date Of Hearing : 05.05.2025 Date Of Pronouncement : 25.06.2025

For Appellant: Shri K.M. Gupta, Advocate &For Respondent: Ms Ekta Jain, CIT-DR
Section 115ASection 115A(1)(a)Section 143(3)Section 144CSection 194LSection 3

debentures are issued. To treat CCD and OCD as shares in praesentia would be extending too far the principles of interpretation and infact the purposive interpretation would require extending benefit to the assessee as long as the OCD/CCD are rupee denominated, when investment is sought or interest is paid. Thus

Assistant Commissioner of Income Tax, Circle-1(1)(1), Meerut vs. Prem Sapra, New Delhi

The appeal of the revenue is dismissed

ITA 1739/DEL/2024[2021-22]Status: DisposedITAT Delhi20 Jun 2025AY 2021-22

Bench: Smt. Annapurna Gupta & Ms. Madhumita Royassessment Year: 2021-22

Section 143(3)Section 54

Income Tax Act and it is also said that equity and tax are strangers to each other, still this Court has often observed that purposive interpretation should be given to the provisions of the Act. In the case of Oxford University Press v. CIT [2001] 247 ITR 658/115 Taxman ... this Court has observed that a purposive interpretation of the provisions of the Act should be given while considering a claim for exemption from tax. It has also been said that harmonious construction of the provisions which subserve the object and purpose should also be made while construing

Dharmbhaskar Rashtrasant Shripachlegavkar Maharj Pratishtan, Pune vs. Exemption Ward 1(2), Pune

In the result, both the appeals of the assessee in ITA No

ITA 2799/PUN/2024[2012-13]Status: DisposedITAT Pune18 Jun 2025AY 2012-13
For Appellant: Shri Abhay Shastri & Jasraj SutarFor Respondent: Shri Akhilesh Srivastava
Section 11Section 11(1)(d)Section 12Section 12ASection 143(3)Section 147Section 2(24)

ADIT (Exemption) in the present case] were two well established principles of law. In view of the above and going by the principle of purposive interpretation of statues, an assessment proceeding which is pending in appeal before the appellate authority should be deemed to be ‘assessment proceedings pending before

Dharmbhaskar Rashtrasant Shripachlegavkar Maharj Pratishtan, Pune vs. Exemption Ward 1(2), Pune

In the result, both the appeals of the assessee in ITA No

ITA 2736/PUN/2024[2011-12]Status: DisposedITAT Pune18 Jun 2025AY 2011-12
For Appellant: Shri Abhay Shastri & Jasraj SutarFor Respondent: Shri Akhilesh Srivastava
Section 11Section 11(1)(d)Section 12Section 12ASection 143(3)Section 147Section 2(24)

ADIT (Exemption) in the present case] were two well established principles of law. In view of the above and going by the principle of purposive interpretation of statues, an assessment proceeding which is pending in appeal before the appellate authority should be deemed to be ‘assessment proceedings pending before

Polycab India Limited, Mumbai vs. The Assistant Commissioner of Income-Tax, Circle 5(2), Mumbai

In the result, all the appeals of the assessee are allowed

ITA 4673/MUM/2023[2018-19]Status: DisposedITAT Mumbai16 Jun 2025AY 2018-19

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

Section 115Section 237Section 9

amount liable to be DDT. Any construction to the contrary would antamount to penalising compliance for statutory exemption and alien to taxation laws and purposive interpretation. Accordingly, we hold the purpose of DDT. 25. Accordingly, in our view we hold that amount of dividend paid to IFC should be reduced

Polycab India Limited, Mumbai vs. The Assistant Commissioner of Income-Tax, Circle 5(2), Mumbai

In the result, all the appeals of the assessee are allowed

ITA 4671/MUM/2023[2020-21]Status: DisposedITAT Mumbai16 Jun 2025AY 2020-21

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

Section 115Section 237Section 9

amount liable to be DDT. Any construction to the contrary would antamount to penalising compliance for statutory exemption and alien to taxation laws and purposive interpretation. Accordingly, we hold the purpose of DDT. 25. Accordingly, in our view we hold that amount of dividend paid to IFC should be reduced

Kautilaya Edurchar Trust, Bhavnagar vs. The CIT(Exemption), Ahmedabad

In the result, appeal filed by assessee is allowed for statistical purposes

ITA 496/AHD/2025[NA]Status: DisposedITAT Ahmedabad10 Jun 2025

Bench: Ms. Suchitra Kamble & Shri Makarand V. Mahadeokarआयकर अपील सं /Ita No. 496/Ahd/2025 िनधा"रण वष" /Assessment Year : Na

For Appellant: Shri Mohit Balani, ARFor Respondent: Shri Durga Dutt, CIT.DR
Section 12ASection 12A(1)Section 12A(1)(ac)

settled principle of law that procedural lapses should not defeat substantive rights. It is also settled principle that a liberal and purposive interpretation must be adopted in matters involving registration under section 12A/12AB, especially where compliance is otherwise satisfactory. 8. In view of the above discussion and considering the directive

Radhika Devcon Private Limited, Indore vs. ITO-4(1), Indore

In the result, appeal of the assessee is dismissed

ITA 636/IND/2024[2015-16]Status: DisposedITAT Indore09 Jun 2025AY 2015-16

Bench: Smt. Annapurna Gupta, Accountant Amember & Shri Paresh M. Joshiassessment Year: 2015-16

Section 143(3)Section 263Section 40A(3)

Rules, 1962. 6.3 The contention of the Ld. Counsel for the assessee before us is that the Section has to be given a purposive interpretation and the purpose of introducing Section 40A(3) of the Act being to curb evasion of tax and the transactions undoubtedly being genuine, the provisions

Assistant Commissioner of Income Tax, Central Circle 3(1), Kolkata vs. Rungta Irrigation Ltd, New Dehi

In the result, all the appeals of the assessee are allowed and all the appeals of the revenue stand dismissed

ITA 2401/KOL/2024[2015]Status: DisposedITAT Kolkata15 May 2025

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm]

Section 133ASection 143Section 143(3)Section 147Section 148Section 151

interpretation of a statute in every system of interpretation is the literal rule of interpretation. The other rules of interpretation e.g. the mischief rule, purposive interpretation, etc. can only be resorted to when the plain words of a statute are ambiguous or lead to no intelligible results or if read ... interpretation of a statute in every system of interpretation is the literal rule of interpretation. The other rules of interpretation e.g. the mischief rule, purposive interpretation etc. can only be resorted to when the plain words of a statute are ambiguous or lead to no intelligible results or if read

Assistant Commissioner of Income Tax, Central Circle-3(1), Kolkata vs. Rungta Irrigation Ltd, New Delhi

In the result, all the appeals of the assessee are allowed and all the appeals of the revenue stand dismissed

ITA 2400/KOL/2024[2014]Status: DisposedITAT Kolkata15 May 2025

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm]

Section 133ASection 143Section 143(3)Section 147Section 148Section 151

interpretation of a statute in every system of interpretation is the literal rule of interpretation. The other rules of interpretation e.g. the mischief rule, purposive interpretation, etc. can only be resorted to when the plain words of a statute are ambiguous or lead to no intelligible results or if read ... interpretation of a statute in every system of interpretation is the literal rule of interpretation. The other rules of interpretation e.g. the mischief rule, purposive interpretation etc. can only be resorted to when the plain words of a statute are ambiguous or lead to no intelligible results or if read

Assistant Commissioner of Income Tax, Central Circle-3(1), Kolkata vs. Rungta Irrigation Limited, New Delhi

In the result, all the appeals of the assessee are allowed and all the appeals of the revenue stand dismissed

ITA 2399/KOL/2024[2012]Status: DisposedITAT Kolkata15 May 2025

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm]

Section 133ASection 143Section 143(3)Section 147Section 148Section 151

interpretation of a statute in every system of interpretation is the literal rule of interpretation. The other rules of interpretation e.g. the mischief rule, purposive interpretation, etc. can only be resorted to when the plain words of a statute are ambiguous or lead to no intelligible results or if read ... interpretation of a statute in every system of interpretation is the literal rule of interpretation. The other rules of interpretation e.g. the mischief rule, purposive interpretation etc. can only be resorted to when the plain words of a statute are ambiguous or lead to no intelligible results or if read

Rungta Irrigation Limited, New Delhi vs. A.C.I.T., Central Circle 3(1), Kolkata

In the result, all the appeals of the assessee are allowed and all the appeals of the revenue stand dismissed

ITA 2316/KOL/2024[2015-16]Status: DisposedITAT Kolkata15 May 2025AY 2015-16

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm]

Section 133ASection 143Section 143(3)Section 147Section 148Section 151

interpretation of a statute in every system of interpretation is the literal rule of interpretation. The other rules of interpretation e.g. the mischief rule, purposive interpretation, etc. can only be resorted to when the plain words of a statute are ambiguous or lead to no intelligible results or if read ... interpretation of a statute in every system of interpretation is the literal rule of interpretation. The other rules of interpretation e.g. the mischief rule, purposive interpretation etc. can only be resorted to when the plain words of a statute are ambiguous or lead to no intelligible results or if read

Rungta Irrigation Limited, Delhi vs. A.C.I.T., Central Circle 3(1), Kolkata

ITA 2315/KOL/2024[2013-14]Status: DisposedITAT Kolkata15 May 2025AY 2013-14

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm]

Section 133ASection 143Section 143(3)Section 147Section 148Section 151

ITA Nos. 2257, 2303, 2315 & 2316/Kol/2024 & ITA Nos. 2399, 2400 & 2401/Kol/2024 Rungta Irrigation Ltd. THE INCOME TAX APPELLATE TRIBUNAL “D

Rungta Irrigation Limited, New Delhi vs. D.C.I.T., Central Circle - 3(1), Kolkata

ITA 2303/KOL/2024[2014-15]Status: DisposedITAT Kolkata15 May 2025AY 2014-15

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm]

Section 133ASection 143Section 143(3)Section 147Section 148Section 151

THE INCOME TAX APPELLATE TRIBUNAL “D” BENCH, KOLKATA [Before Shri Rajesh Kumar, AM & Shri Pradip Kumar Choubey, JM] Ι.Τ

Rungta Irrigation Limited, Delhi vs. Central Circle 3(1)/Kolkata, Kolkata

In the result, all the appeals of the assessee are allowed and all the appeals of the revenue stand dismissed

ITA 2257/KOL/2024[2012-13]Status: DisposedITAT Kolkata15 May 2025AY 2012-13

Bench: Shri Rajesh Kumar, Am & Shri Pradip Kumar Choubey, Jm]

Section 133ASection 143Section 143(3)Section 147Section 148Section 151

interpretation of a statute in every system of interpretation is the literal rule of interpretation. The other rules of interpretation e.g. the mischief rule, purposive interpretation, etc. can only be resorted to when the plain words of a statute are ambiguous or lead to no intelligible results or if read ... interpretation of a statute in every system of interpretation is the literal rule of interpretation. The other rules of interpretation e.g. the mischief rule, purposive interpretation etc. can only be resorted to when the plain words of a statute are ambiguous or lead to no intelligible results or if read

Asstt. Commissioner of Income Tax (Exemptions), Circle, Pune vs. Zeal Education Society, Pune

In the result, appeal of the Revenue is dismissed

ITA 1642/PUN/2024[2017-2018]Status: DisposedITAT Pune08 May 2025AY 2017-2018

Bench: Shri Manish Borad & Ms. Astha Chandra

For Appellant: Shri S.N. Puranikh, CAFor Respondent: Shri Arvind Desai, Addl.CIT-DR
Section 11Section 11(1)Section 11(1)(a)Section 12ASection 143(3)Section 270ASection 274

erred in deleting the penalty solely stating that the assessed income should be more than the income processed under section 143(1), whereas on purposive interpretation the income assessed can be treated as more than what could have been determined on processing and alternatively Ld. CIT(A) has erred

Raniwala Jewellers Private Limited, Jaipur vs. ACIT/DCIT Cir-6, Jpr, Jaipur

In the result, the appeal of the assessee is allowed

ITA 10/JPR/2025[2023-24]Status: DisposedITAT Jaipur06 May 2025AY 2023-24

Bench: Shri Gagan Goyal & Shri Narinder Kumar

For Appellant: Mr. Nikhilesh Kataria, C.A., Ld. ARFor Respondent: Mrs. Anita Rinesh, JCIT, Ld. DR
Section 10BSection 10B(8)Section 139Section 139(1)Section 139(5)Section 143(1)Section 250Section 80J

reiterated that strict interpretation of a statute certainly involves literal or plain meaning test. The other tools of interpretation, namely contextual or purposive interpretation cannot be applied nor any resort be made to look to other supporting material, especially in taxation statutes. Indeed, it is well settled that

Barminco Indian Underground Mining Services LLP, Delhi vs. DCIT, Circle-28(1), Delhi

In the result, appeal of the Revenue is dismissed

ITA 2253/DEL/2022[2020-21]Status: DisposedITAT Delhi04 Apr 2025AY 2020-21

Bench: Shri Vikas Awasthy & Shri Avdhesh Kumar Mishraआअसं.2253/िद"ी/2010(िन.व. 2006-07) Deputy Commissioner Of Income Tax, Circle-31(1), R. No. 1405, 14Th Floor, E-2 Block, Pratyakshkar Bhawan, Civic Centre, Jln Marg, ...... अपीलाथ"/Appellant New Delhi बनाम Vs. Niranjan Koirala, 27, Akbar Road, New Delhi ..... "ितवादी/Respondent Pan: Aaupk-0483-B Assessee By : Shri Tarandeep Singh, Advocate Department By : Shri Manoj Kumar, Sr. Dr सुनवाई क" ितिथ/ Date Of Hearing : 23.05.2025 घोषणा क" ितिथ/ Date Of Pronouncement : : 19.08.2025 आदेश/Order Per Vikas Awasthy, Jm: This Appeal By The Revenue Is Directed Against The Order Of Commissioner Of Income Tax (Appeals)-Xxx, New Delhi (Hereinafter Referred To As 'The Cit(A)') Dated 18.02.2010, For Assessment Year 2006-07. 2. This Appeal Was Decided By The Tribunal Vide Order Dated 20.07.2018. Thereafter, The Revenue Filed Miscellaneous Application Seeking Rectification In The Order Of Tribunal On The Ground That The Additional Grounds Of Appeal Raised By The Revenue Vide Application Dated 13.08.2014 Remained To Be Decided. The Tribunal In Ma No. 732/Del/2018 Vide Order Dated 10.07.2023 Recalled The Order

For Appellant: Shri Tarandeep Singh, AdvocateFor Respondent: Shri Manoj Kumar, Sr. DR
Section 54F

which was pronounced in Smt. Tarulata Shyam Vs. CIT 108 ITR 345 (SC). It is also well settled that there is no room for purposive interpretation under the direct tax laws and in this connection one may advert to the ratios in (1998) 234 ITR 261 (MP) Laxmandas Pranchand

Classic Mall Development Company Limited, Mumbai vs. Assistant Commissioner of Income Tax, Circle 6(2)(1), Mumbai

In the result, appeal of the assessee is allowed

ITA 5320/MUM/2024[2016-17]Status: DisposedITAT Mumbai21 Mar 2025AY 2016-17

Bench: Shri Amit Shukla & Shri Girish Agrawalassessment Year: 2016-17

For Appellant: Shri Vijay Mehta, CAFor Respondent: Shri R.A. Dhyani, CIT DR &
Section 143(3)Section 23(1)Section 23(1)(a)

situation where a property is let out and at the same time “vacant for the whole year”. Thus, by applying the principles of purposive interpretation to section 23(1)(c) and not to render the words “vacant for the whole year” infructuous, the word “let” used in the said section

Ych Logistics India Private Limited, Kanchipuram, Tamilnadu vs. Assistant Commissioner of Income Tax, Corporate Circle -3(2), Chennai

In the result the appeal of the assessee is partly allowed for statistical purposes

ITA 1330/CHNY/2023[2012-13]Status: DisposedITAT Chennai19 Mar 2025AY 2012-13

Bench: Shri George George K, Hon’Ble & Shri S.R. Raghunatha, Hon’Bleआयकरअपीलसं./Ita No.: 1330/Chny/2023 िनधा"रणवष" / Assessment Year: 2012-13 Ych Logistics India Private Ltd., Assistant Commissioner Of Plot D V 1, Hi-Tech Sez Phase Ii, V. Income Tax, Sirumangadu Village, Sriperumbudur Corporate Circle -3(2), Taluk, Tamil Nadu 602 105. Chennai. [Pan: Aaacy-2873-L] (अपीलाथ"/Appellant) (""यथ"/Respondent)

For Appellant: Shri. Ajit Kumar Jain, CA by VirtualFor Respondent: Shri. A. Sasikumar, CIT
Section 10ASection 250Section 92C(3)Section 92D

Learned CIT(A) and AO failed to appreciate that the object for granting concession/ exemption should not be lost sight of and a purposive interpretation must be adopted. 3.11 The Learned CIT(A) and AO erred in law and in principle by denying the claim of deduction under section 10AA