https://www.taxtmi.com/caselaws?id=235426 A rehabilitation scheme sanctioned under the Sick Industrial Companies (Special Provisions) Act, 1985 could validly provide waiver and reduction of income-tax interest despite mandatory interest provisions in the Income-tax Act, because section 32 gave the special statute and its scheme overriding effect over inconsistent laws. Applying harmonious construction and the principle that a special enactment prevails over a general one, the Court treated the interest relief as a lawful part of the restructuring package. The Income-tax Department could not defeat the sanctioned scheme by relying on section 119 or internal circulars, since those administrative instructions cannot override a statutory rehabilitation scheme and the department had already participated in and acted upon the process. en-us Fri, 19 Jul 2013 00:00:00 +0530 Tue, 23 Jul 2013 10:17:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=235426 A rehabilitation scheme sanctioned under the Sick Industrial Companies (Special Provisions) Act, 1985 could validly provide waiver and reduction of income-tax interest despite mandatory interest provisions in the Income-tax Act, because section 32 gave the special statute and its scheme overriding effect over inconsistent laws. Applying harmonious construction and the principle that a special enactment prevails over a general one, the Court treated the interest relief as a lawful part of the restructuring package. The Income-tax Department could not defeat the sanctioned scheme by relying on section 119 or internal circulars, since those administrative instructions cannot override a statutory rehabilitation scheme and the department had already participated in and acted upon the process. Case-Laws Income Tax Fri, 19 Jul 2013 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=235426