The Commissioner Of Income-Tax, West ... vs M/S. Vegetables Products Ltd on 29 January, 1973
24. Thus, there are two views on the issue; one is in favour of the revenue and the other in favour of the assessee. We find guidance from the judgment of Honble Supreme Court in the matter of CIT v. Vegetable Products Ltd. (1972) 88 ITR 192. Honble Supreme Court has laid down a principle that "if two reasonable constructions of a taxing provisions are possible, that construction which favours the assessee must be adopted." This principle has been consistently followed by the various authorities as also by the Honble Supreme Court itself. Therefore, looking to the nature of the provisions with which we are presently concerned, we are inclined to adopt the interpretation which is in favour of the assessee. We, therefore, reverse the order of the lower authority and hold that no interest under sections 234B and 234C is chargeable while computing the income of the assessec in terms of Section 115J of the Act.