| Case ID |
de2e6787-1bbf-488b-b06b-d67a83c3e1c9 |
| Body |
View case body. Login to View |
| Case Number |
TAX CASE Nos. 193 AND 194 OF 1976 |
| Decision Date |
Nov 13, 1979 |
| Hearing Date |
|
| Decision |
The Madras High Court upheld the Tribunal's decision that the assessee was entitled to the relief of 6% on the capital employed without any limitation on a proportionate time basis. The court emphasized that provisions for exemptions should be construed liberally, and that the expression 'per annum' in the context of the Income-tax Act should not restrict the relief granted to the assessee based on the duration of machinery use. The ruling affirmed that the interpretation of statutory provisions should favor the taxpayer, reinforcing the principle that fiscal statutes must be interpreted in a manner that promotes economic growth and industrialization. |
| Summary |
In the case of Commissioner of Income Tax v. Simpson & Co., the Madras High Court addressed the interpretation of Section 84 of the Income-tax Act, 1961, which provides tax relief on profits from new industrial undertakings. The core issue revolved around whether the relief of 6% on capital employed should be proportionately adjusted based on the actual usage of machinery. The court ruled in favor of the assessee, establishing that such provisions should be liberally construed to promote industrial growth. The decision underscores the importance of understanding statutory language in fiscal matters, where the intent is to support economic development. This case is significant for tax practitioners and businesses seeking clarity on tax relief provisions, as it reinforces the principle that exemptions should not be unduly limited by technical interpretations. |
| Court |
Madras High Court
|
| Entities Involved |
Not available
|
| Judges |
Sethuraman, J.,
Balasubramanian, J.
|
| Lawyers |
J. Jayaraman,
Mrs. Nalini Chidambaram,
S.V. Subramaninn
|
| Petitioners |
Commissioner of Income Tax
|
| Respondents |
Simpson & Co.
|
| Citations |
1980 SLD 797,
(1980) 122 ITR 283
|
| Other Citations |
Rex v. General CIT [1942] 24 TC 221 (HL)
|
| Laws Involved |
Income-tax Act, 1961
|
| Sections |
84
|