https://www.taxtmi.com/caselaws?id=790786 An inclusive definition of "Joint Commissioner" in the Income-tax Act can encompass an Additional Commissioner for prior approval under Section 274(2), unless the statutory context clearly excludes that meaning. Applying harmonious construction, the Kerala High Court noted that Section 2(28C) expressly includes an Additional Commissioner, and found no repugnancy in Section 274(2) to displace that definition. The result was that prior approval by the Additional Commissioner was treated as valid compliance for penalty proceedings under Sections 271D and 271E, and the challenge to those proceedings failed. en-us Wed, 08 Apr 2026 00:00:00 +0530 Thu, 30 Apr 2026 07:19:15 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=790786 An inclusive definition of "Joint Commissioner" in the Income-tax Act can encompass an Additional Commissioner for prior approval under Section 274(2), unless the statutory context clearly excludes that meaning. Applying harmonious construction, the Kerala High Court noted that Section 2(28C) expressly includes an Additional Commissioner, and found no repugnancy in Section 274(2) to displace that definition. The result was that prior approval by the Additional Commissioner was treated as valid compliance for penalty proceedings under Sections 271D and 271E, and the challenge to those proceedings failed. Case-Laws Income Tax Wed, 08 Apr 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=790786