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Assistant Commissioner Of Income-Tax vs Amadeus India (P.) Ltd. on 17 January, 2001 cites

H.H. Maharaja Rana Hemant Singhji vs Commissioner Of Income-Tax on 2 December, 1969

Thus only one programme was available to one agent unless he asked for more programmes. The Id. counsel further argued that there are certain words used in the Income-tax Act and Customs Act. Unless the meaning of the words in both the Acts were contrary to each other these should be considered together. He stated that as per doctrine of pari materia this has to be considered so. For this purpose reliance was placed on the decisions in State of Assam v.Deva Prasad Barua [1970] 75 ITR 18 (SC) and H.H. Maharaja Rana Hemant Singhji v. CIT [1976] 103 ITR 61 (SC). It was also argued that the meaning of a particular word should be adopted which was more compatible to the entire word unless the contrary meaning was given to a particular Act. He stated that at page 2 of his order the Assessing Officer has admitted that the assessee was engaged in the export. His objection was that what was being exported by the assessee was only "processed data" and not "Computer programme". The Id. counsel wounded of his arguments by stating that the assessee was preparing a Computer Software Programme and was exporting the same through computers. The Commissioner (Appeals) has rightly appreciated these facts and allowed relief to the assessee under section 80HHE of the Act.
Rajasthan High Court - Jaipur Cites 17 - Cited by 15 - Full Document
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