Clear statutory language bars implied set-off of pre-amendment loss against firm income after assessable-unit change.

After the 1994 amendment to the Karnataka Agricultural Income-tax Act, 1957, the firm became the assessable unit, and the statute did not expressly permit a partner to set off unabsorbed pre-1 April 1994 loss against the firm's income. The Court stated that legislative speech or purposive construction may be used only where the statutory language is ambiguous; when the text is clear, no additional relief can be read in or created by interpretation. Because the Act contained no provision comparable to the one relied on under the Income-tax Act, the claimed set-off was unavailable and the amendment was not unconstitutional on that ground.

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Issues: Whether, after the 1994 amendment to the Karnataka Agricultural Income-tax Act, 1957, a partner could claim set-off of unabsorbed loss incurred prior to 1 April 1994 against the income of the firm; and whether the amendment creating the firm as the assessable unit was unconstitutional for not providing such set-off.

Analysis: The statutory scheme before 1 April 1994 treated partners as the assessable units and permitted carry forward and set-off of a partner's loss under the relevant provisions. After the amendment, the firm became the assessable unit and the Act did not contain any express provision allowing a partner's prior loss to be set off against the firm's income. The Court held that interpretive aids such as legislative speech or purposive construction can be invoked only where the statutory language is ambiguous. Where the text is clear, the Court cannot add words or extend a benefit not provided by the legislature. The absence of a provision analogous to the one relied upon under the Income-tax Act meant that the claimed set-off could not be granted, and the amendment was not rendered unconstitutional on that ground.

Conclusion: The claim for set-off was rejected and the constitutional challenge failed.

Final Conclusion: The amendment was upheld, and the writ petition was dismissed as the petitioners were not entitled to the claimed set-off of losses against the firm's income.

Ratio Decidendi: Where the statute is clear and unambiguous, the Court cannot read in a set-off or other relief not expressly provided, and interpretive aids cannot be used to create a benefit contrary to the plain statutory scheme.

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