ITO v. Vikram Sujitkumar Bhatia (2023)453 ITR 417/ 293 Taxman 4/ 332 CTR 1/ 224 DTR 217 (SC)

Interpretation of taxing statutes -Interpretation which effectuates object and purpose of statute preferred.-Amendment by substitution-Rule against retrospectivity. [S. 153C]

Court held that while interpreting machinery provisions of a taxing statute, the court must give effect to its manifest purpose by construing it in such a manner as to effectuate the object and purpose of the statute. Once the primary intention is ascertained and the object and purpose of the legislation is known, it becomes the duty of the court to give the statute a purposeful or a functional interpretation. The ascertainment of the legislative intent is a basic rule of statutory construction and a construction should be preferred which advances the purpose and object of a legislation.