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Interpretation of the term 'income' in Section 28 of the Income Tax Act. Analysis: The judgment revolves around the interpretation of the term 'income' as used in Section 28 of the Income Tax Act. The petitioner argues that 'income' refers only to money received by the assessee and does not include deductions or exemptions claimed. On the contrary, the income tax authorities assert that 'income' has a broader meaning, encompassing the assessable figure after accounting for deductions and exemptions. The court delves into various sections of the Income Tax Act to decipher the true connotation of 'income', highlighting that the term is used in a technical sense rather than its popular meaning. Sections 2(15), 3, 4, and others outline the computation of total income, chargeable income, heads of income, and methods of computing income under different categories. The court emphasizes that adopting the petitioner's interpretation would lead to absurd outcomes, allowing assessees to manipulate deductions while truthfully reporting income, which goes against the legislative intent. Moving forward, the judgment references a case involving bad debts to support the notion that deductions are necessary for arriving at the true profits and gains of a business. The court underscores that falsehood in accounts can manifest through suppression or fraudulent claims, both of which are penalized under Section 28. In the present case, it was established that the assessee deliberately made a false deduction. Drawing from the precedent and legal principles, the court concludes that the assessee's actions fell within the purview of Section 28, leading to the dismissal of the petition with costs. In essence, the judgment clarifies the comprehensive understanding of 'income' in the context of the Income Tax Act, emphasizing the technical interpretation over the popular understanding. It underscores the importance of accurate reporting, penalizing both concealment and deliberate inaccuracies in income particulars to maintain the integrity of the tax regime.
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