Allowing the reference of the assessee the Court states that in fact , the written submission of revenue , states “ Litera leges , certainty concept and the concept that there is no equity on fiscal law irrespective of any judgement of any Honourable Court or Tribunal to go –by cannot be given to the aforesaid interpretations given in this written submission “
The above submission that decision of Court and/ or Tribunal interpreting a provision is to be ignored by the Assessing Officer , if accepted will ring the death knell of Rule of law in the Country. The Assessing Officer is bound by the views of the Court. The above submission ignores the hierarchical system of jurisprudence in our country. ( ITA No. 25 of 2000, dt. 23.02.2018)( AY.1993-94)