Vehicle expense apportionment and agricultural income substantiation: ITAT allowed partial business deduction and deleted the reclassification additio...
IS 16731/ISO 8217 was treated as a marine-fuel standard, and its scope, safety clauses and flash-point requirements were read contextually to confine Distillate Marine Oil to use on board ships. Applying ejusdem generis, the reference to stationary diesel engines of the same or similar type as marine engines was held not to extend the fuel to industrial use generally, so the petitioner's wider end-use contention failed. The Court also declined to rewrite the prescribed end-use declaration, holding that the maritime regulatory conditions were not shown to be illegal or manifestly arbitrary. Provisional release was therefore made conditional on execution of the declaration in the form required by the authorities, and the writ petition was dismissed.
IS 16731/ISO 8217 was treated as a marine-fuel standard, and its scope, safety clauses and flash-point requirements were read contextually to confine Distillate Marine Oil to use on board ships. Applying ejusdem generis, the reference to stationary diesel engines of the same or similar type as marine engines was held not to extend the fuel to industrial use generally, so the petitioner's wider end-use contention failed. The Court also declined to rewrite the prescribed end-use declaration, holding that the maritime regulatory conditions were not shown to be illegal or manifestly arbitrary. Provisional release was therefore made conditional on execution of the declaration in the form required by the authorities, and the writ petition was dismissed.
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