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Genpact India Private Limited vs Deputy Commissioner Of Income Tax on 22 November, 2019

10.5. A submission is also made raising doubt over the maintainability of the appeal under Section 246-A of the Act. We have no hesitation in holding that the appeal is maintainable. The very case of the respondent is that the appellant ought to have shown its return the transactions as dividend and not capital gain. Therefore, it is a case of an improper return having been filed. Considering some what similar objection raised on a slightly different fact involving a demand raised under Section 115Q of the Act, a Division Bench of Delhi High Court in Genpact India (P) Limited Vs. Deputy Commissioner of Income-Tax ((2019) 108 Taxmann.com 340(Delhi) was pleased to hold that the appeal would certainly be maintainable. Therefore, any order involving civil consequence has to be termed as final, entitling an assessee in challenging the same before the appellate forum. Certainly, a purposive interpretation is required to be adopted. In a procedural law which provides for an appeal, a technical interpretation is required to be eschewed.
Supreme Court of India Cites 86 - Cited by 250 - U U Lalit - Full Document
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