Inclusive statutory definition governs approval requirement; Additional Commissioner's prior approval satisfied the penalty provision.

An inclusive statutory definition must be applied throughout the Act unless the context clearly excludes it. For Section 274(2), the definition of "Joint Commissioner" in Section 2(28C), which includes an Additional Commissioner appointed under Section 117(1), was held to govern the approval requirement for penalty proceedings under Sections 271D and 271E. The Act disclosed no contextual basis to exclude the Additional Commissioner, and references to both authorities elsewhere did not override the definition. Prior approval granted by the Additional Commissioner therefore satisfied the statutory requirement, and the challenge to the penalty proceedings for want of approval by the Joint Commissioner was rejected.

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Issues: Whether prior approval granted by the Additional Commissioner satisfied the requirement of prior approval of the Joint Commissioner under Section 274(2) for imposing penalty under Sections 271D and 271E.

Analysis: Section 2(28C) defines "Joint Commissioner" to include an Additional Commissioner appointed under Section 117(1), and that definition governs the Act unless the context otherwise requires. The scheme of the Act did not disclose any contextual exclusion of the Additional Commissioner from the expression "Joint Commissioner" in Section 274(2). The presence of explicit references to both authorities in other provisions did not dilute the statutory definition, and a harmonious construction required giving effect to the inclusive definition rather than rendering it otiose. The prior approval obtained from the Additional Commissioner therefore answered the statutory requirement.

Conclusion: The challenge to the penalty proceedings on the ground of absence of approval by the Joint Commissioner was rejected.

Ratio Decidendi: A defined statutory expression must be given its inclusive meaning throughout the enactment unless the context clearly excludes it, and prior approval by an authority included within the definition satisfies the statutory requirement.

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