https://www.taxtmi.com/caselaws?id=790786 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. en-us Wed, 08 Apr 2026 00:00:00 +0530 Thu, 30 Apr 2026 07:19:12 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=790786 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. Case-Laws Income Tax Wed, 08 Apr 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=790786