https://www.taxtmi.com/caselaws?id=289635 Section 10A of the Indian Excess Profits Tax Act, 1940 was treated as a special appellate code for decisions on the purpose of a transaction and the resulting adjustment. The general appeal route under section 17(1) applied to assessment matters as such, not to the specific section 10A decision. Reading both routes as available for the same grievance would create anomalous concurrent appeals to the same Tribunal. Applying the principle that a special provision prevails over a general one, the section 10A appeal was treated as the exclusive remedy for that issue, and a section 17(1) appeal was considered incompetent for the section 10A decision. en-us Mon, 10 Nov 1947 00:00:00 +0530 Mon, 10 Aug 2020 15:32:19 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=289635 Section 10A of the Indian Excess Profits Tax Act, 1940 was treated as a special appellate code for decisions on the purpose of a transaction and the resulting adjustment. The general appeal route under section 17(1) applied to assessment matters as such, not to the specific section 10A decision. Reading both routes as available for the same grievance would create anomalous concurrent appeals to the same Tribunal. Applying the principle that a special provision prevails over a general one, the section 10A appeal was treated as the exclusive remedy for that issue, and a section 17(1) appeal was considered incompetent for the section 10A decision. Case-Laws Income Tax Mon, 10 Nov 1947 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=289635