Meaning of “Before the specified date”

Case Name : Chandra Kumar Seth Vs. ITo

Citation : [1997] 62 ITD 106/95 taxman 113 (all. – Trib.) (Mag.)

Court : ITAT-Allahabad

Section : 44ab

Meaning : The meaning of the word ‘before’ in section 44ab of the act is cloudy and uncertain. The word is possible of two meanings, one being the common meaning and other as given in chamber’s twentieth century dictionary as ‘previous to the expiration of’. Looking to the other sections of the act and giving harmonious construction and applying the ratio of the decision of the bombay high court in premchand nathmal kothari v. Kisanal bachharaj vyas air 1976 bom. 82 The expression ‘before the specified date’ in section 44ab means ‘on or before the specified date’.

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