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Ts Tech Sun India Private Limited ,New ... vs The Assistant Commissioner Of Income ... on 28 January, 2026 cites

M/S. Sun Tech City Pvt. Ltd., ... vs Acit, Corporate Circle-1(2), ... on 22 August, 2017

17. The concept of "absurdity" in the context of interpretation of statutes is construed to include any result which is unworkable, impracticable, illogical, futile or pointless, artificial, or productive of a disproportionate counter-mischief [ SeeBennion on Statutory Interpretation, 5th Edn., p.969.] . Logic referred to herein is not formal or syllogistic logic, but acceptance that enacted law would not set a standard which is palpably unjust, unfair, unreasonable or does not make any sense. [Bennion on Statutory Interpretation, 5th Edn., p. 986.] When an interpretation is beset with practical difficulties, the courts have not shied from turning sides to accept an interpretation that offers a pragmatic solution that will serve 18 ITA No. 4391/Del/2024 T S Tech Sun India Pvt. Ltd. Vs. ACIT the needs of society [Id, p. 971, quoting Griffiths, L.J.] .Therefore, when there is choice between two interpretations, we would avoid a "construction" which would reduce the legislation to futility, and should rather accept the "construction" based on the view that draftsmen would legislate only for the purpose of bringing about an effective result. We must strive as far as 24 possible to give meaningful life to enactment or rule and avoid cadaveric consequences [See Principles of Statutory Interpretation by Justice G.P. Singh, 14th Edn., p. 50.]"
Income Tax Appellate Tribunal - Cuttack Cites 0 - Cited by 1 - Full Document

Shelf Drilling J. T. Angel Ltd., Mumbai vs Dy. C.I.T. (International Taxation) - ... on 4 October, 2019

19. We further noted that, although the decisions of the Hon'ble Madras High Court in the case of CIT Vs. Roca Bathroom Products Private Limited (supra) and the Hon'ble Bombay High Court in the case of Shelf Drilling Ron Tappmeyer Limited Vs. ACIT, International Taxation (supra) are in favour of the assessee, and we dispose of the appeal filed by the assessee by following the above two decisions and quashed the assessment order, but the fact remains that the revenue has challenged the decision of the Hon'ble Bombay High Court in the case of Shelf Drilling Ron Tappmeyer Limited Vs. ACIT, International Taxation (supra) by filing an SLP before the Hon'ble Supreme Court, and the Hon'ble Supreme Court has disposed of the appeal. Further, the Hon'ble Supreme Court has delivered a split verdict by two Hon'ble Judges on this issue, i.e., one in favour of the revenue and one in favour of the assessee.
Income Tax Appellate Tribunal - Mumbai Cites 14 - Cited by 4 - Full Document

Comer Industries India Private ... vs Assessment Unit Income Tax Department, ... on 27 February, 2023

In view of the ratio laid down by the Hon'ble High Court of Madras in the case of Roca Bathroom Products Pvt. Ltd (supra), also relying on the plethora of orders passed by the Co-ordinate Bench of the Tribunal of Hyderabad Bench (supra) and the decision of the Co-ordinate Bench of the Tribunal in the case of Teva Pharmaceutical & chemical Industries India Private Limited Vs. Assessment Unit, Income Tax Department/DCIT(supra), in order to follow the principals of consistency as mere keeping the captioned Appeal pending in the Tribunal will not serve any purpose, by respectfully following those binding precedents, we hold that the impugned Final Assessment Order passed u/s 143(3) r.w.s. 144C(13) of the Act dated 26/07/2024 pertaining to Assessment 25 ITA No. 4391/Del/2024 T S Tech Sun India Pvt. Ltd. Vs. ACIT Year 2020-21 is barred by limitation as per Section 153 r.w. Section 144C of the Act. Accordingly, the impugned Final Assessment Order is hereby quashed.
Income Tax Appellate Tribunal - Bangalore Cites 6 - Cited by 0 - Full Document
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