Wipro Limited vs The Joint Commissioner Of Income Tax on 25 August, 2021
much has been argued on behalf of the assessee that his is
not a case of fresh assessment/re-assessment, and therefore
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the impugned order is liable to be voided, whereas the
Revenue has contended to the contrary; therefore, it becomes
necessary to discuss these concepts. While juxtaposing
contextual construction qua literal interpretation of statutes,
Justice Krishna Iyer in CIT vs. ARAVIND REDDY, AIR 1980
SC 96 observed: