M/S.VIRTUAL SOFT SYSTEMS LTD. vs. COMMISSIONER OF INCOME TAX, DELHI-I
C.A. No.-007115-007115 - 2005Supreme Court06 Feb 2007
For Respondent: Commissioner of Income Tax, Delhi-I
Section 260ASection 271(1)(c)Section 68
Justice Mahajan in Tolaram Relumal v.
State of Bombay, AIR 1954 SC 496 at pages 498-
499, stated the rule in the following words:
"(I)f two possible and reasonable
constructions can be put upon a penal
provision, the court must lean towards
that construction which exempts the
subject from penalty rather than the one
which imposes penalty
