Legal interpretation of notification

*Whether Extension upto 5th Aug is applicable only to taxpayers having SA Tax payable?*

 

With respect to the Two Extension Notifications issued,

For across India it is mentioned *“for filing such returns”* whereas in J&K it is mentioned *“for filing returns”*. Also for across India it is mentioned *“in case of taxpayers”* whereas in J&K it is mentioned *“in case of the Income-tax assessees”*.

 

_“Ex praecedentibus et consequentibus optima fit interpretation”_ – The best interpretation is made from things preceding and following. The words “Such Returns” and also difference in drafting of two Notifications create room for ambiguity.

 

On the other hand, the Tweet of Revenue Secretary, Dr. Hasmukh Adhia and a plain vanilla interpretation of the Notification indicates simple extension to 5th Aug whether or not any SA Tax is payable.

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