“Section 64(2)”

The case holds that taxing statutes must be interpreted strictly based on their plain language. Courts should not read anything into the statute, imply intendment, or consider equity, hardship, or injustice.

Leave to appeal was granted by the Supreme Court in this case. The case concerns reassessment proceedings following a search.

The Assessing Officer accepted the assessee's claim of being in the construction business and its use of the project completion method, and the Revenue did not take remedial measures under sections 263 or 147, indicating acceptance of the assessment.

Additions to income cannot be made based on seized documents that are unclear about whether the items represent payments, receipts, or other calculations, especially when corroborative evidence is lacking. Similarly, additions for investments based on seized papers are invalid if the items themselves were not found.

A payment made to eliminate competition is a capital expenditure, not a deductible business expense, as it secures an enduring benefit.

The applicability of Section 115JB provisions is a matter for the Assessing Officer to consider, and judicial precedent, including the UCO Bank case, can be relied upon by the Commissioner (Appeals). However, this precedent may not hold good for assessment years post-amendment, particularly after Explanation 3 to Section 115JB was introduced.

A question of an Assessing Authority's jurisdiction cannot be disputed after assessment proceedings are completed. Such disputes can only be decided by the Commissioner or the Board, not by an appellate authority under Section 246.

Tax liability under a new provision of the Income Tax Act cannot be applied retrospectively to assessment years prior to the date the provision came into force. The date of accrual of income is relevant for determining which provision applies.