Issues Involved: 1. Interpretation of section 33(6) of the Income-tax Act, 1961. 2. Binding nature of High Court decisions on other High Courts. 3. Application of beneficial interpretation in tax law.
Summary:
1. Interpretation of Section 33(6) of the Income-tax Act, 1961: The primary issue was whether the development rebate on the cost of meters installed by the assessee-company at the residential or office premises of its consumers was at variance with the provisions of section 33(6) of the Act. The Tribunal held that the restriction in section 33(6) applied only to machinery and plant installed in the office premises or residential accommodation belonging to or occupied by the assessee. The High Court found no ambiguity in the language of section 33(6) and stated that the restriction applies to any machinery or plant installed in any office premises or residential accommodation, regardless of ownership or occupation by the assessee. However, the High Court agreed with the Tribunal that electric meters do not fall within the category of plant and machinery intended for use in the office or residence as contemplated by section 33(6).
2. Binding Nature of High Court Decisions on Other High Courts: The court addressed whether it was bound to follow the decision of another High Court on an all-India statute like the Income-tax Act. It concluded that the decision of one High Court is not binding on another High Court. The doctrine of stare decisis applies within the same High Court, but decisions of one High Court only have persuasive value for other High Courts. The court emphasized that each High Court must give its own decision on questions of law referred to it, as required by section 260 of the Act.
3. Application of Beneficial Interpretation in Tax Law: The assessee argued that even if the High Court disagreed with the Tribunal's interpretation of section 33(6), it should adopt the interpretation favorable to the assessee, citing Supreme Court decisions that favor the taxpayer in cases of ambiguity. The High Court rejected this argument, stating that beneficial interpretation applies only when the language of the statute is ambiguous or reasonably capable of more than one interpretation. Since the court did not find any ambiguity in section 33(6), it did not apply the principle of beneficial interpretation.
Conclusion: The High Court concluded that the Tribunal was correct in holding that section 33(6) was not applicable to the electric meters installed by the assessee at the residential or office premises of its consumers. Therefore, the assessee was entitled to the development rebate on the cost of these meters. The question referred to the court was answered in the affirmative, in favor of the assessee and against the Revenue.
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