Court held that it is well settled solitary principle that if statute provides for a thing to be done in a particular manner, then it has to be done in that manner and in no other manner. Chandra Kishore Jha v. Mahaveer and others 1999 8 SCC 266 Cherrukurimani v. Chief Secretary Government of Andhra Pradesh and others 2015 13 SCC 722, Municipal Corporation Greater Mumbai v. Abhilash Lal and others 2020 13 SCC 234, Opto Circuit India Limited v. Axis Bank and others 2021 6 SCC 707, Union of India v.. Mahesh Sing (CAP.No.4807 of 2022) , Tata Chemicals Limited v. Commissioner of Customs (preventive) Jam Nager 2015 11 SCC 628. (WP Nos .25903 of 2023 and Ors dt .14 -9 -2023 ( AY. 2016 -17)
Kanakanala Ravindra Reddy and Ors v .UOI ( 2023) 295 Taxman 652 / 334 CTR 646 ( Telangana )(HC) www.itatonline .org
Interpretation of taxing statute – If statute provides for a thing to be done in a particular manner, then it has to be done in that manner and in no other manner – Reassessment – Conducting inquiry, providing opportunity before issue of notice – Faceless Jurisdiction of income -tax authorities. [ S. 148A, Art , 226 ]