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    <title>2026 (5) TMI 185 - MADRAS HIGH COURT</title>
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    <description>Section 36(1)(viia) was construed as giving the assessee the option to choose the permissible mode of claiming the deduction, and that election could not be overridden by the Assessing Officer through rectification under Section 154. The phrase &quot;at its option&quot; was given substantive effect, so a completed and lawful claim could not be re-characterised by the Department as a rectifiable mistake on the facts considered. The assessee&#039;s interpretation was therefore accepted, the deduction claim was upheld, and the departmental challenge failed.</description>
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      <link>https://www.taxtmi.com/caselaws?id=790983</link>
      <description>Section 36(1)(viia) was construed as giving the assessee the option to choose the permissible mode of claiming the deduction, and that election could not be overridden by the Assessing Officer through rectification under Section 154. The phrase &quot;at its option&quot; was given substantive effect, so a completed and lawful claim could not be re-characterised by the Department as a rectifiable mistake on the facts considered. The assessee&#039;s interpretation was therefore accepted, the deduction claim was upheld, and the departmental challenge failed.</description>
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