The dismissal of the special leave petition against the decision of the Delhi High Court in the case of Moser Baer as withdrawn due to there being low tax effect keeping the question of law open could not be held against the Revenue. Chapter III and Chapter VI-A of the Act operate in different realms and the principles of Chapter III, which deals with “incomes which do not form a part of total income”, cannot be equated with the mechanism provided for deductions in Chapter VI-A, which deals with “deductions to be made in computing total income”. Therefore, rulings on the interpretation of Chapter VI-A will not be applicable while considering the claim under section 10B(8) of the Act ( AY. 2001 -02 )
PCIT v. Wipro Ltd. (2022) 446 ITR 1 / 216 DTR 1 / 327 CTR 381/ 288 Taxman 491 / 140 taxmann.com 223 (SC)
Interpretation of taxing statutes–Literal construction-Exemption provisions-Assessee Must Strictly Comply With Conditions. [[S. 10B(5), 10B(8), 72, 80, 139(1), 139(3), 139(5)]