The judgment extensively referenced several key precedents to substantiate the court’s stance:

• The Commissioner of Income Tax vs. M/s Jupiter Bioscience Ltd. - This case was pivotal in determining the applicability of interest under Sections 234B and 234C, emphasizing the temporal aspects of legislative enactments.
• EMAMI LTD. vs. Commissioner of Income Tax - The Calcutta High Court's interpretation in this case reinforced the High Court's decision regarding the non-applicability of interest penalties under specific conditions.
• Central Bank of India vs. State of Kerala and Madhav Rao Jivaji Rao Scindia vs. Union of India - These Supreme Court cases were instrumental in elucidating the scope and interpretation of non obstante clauses within statutes, particularly in relation to promotional exemptions versus mandatory tax provisions.
• Dynamic Orthopedics (P) Ltd. vs. Commissioner of Income Tax - Provided insights into the legislative intent behind the introduction of minimum alternate tax provisions, emphasizing their role in curbing tax avoidance strategies.
• Kishorkumar Prabhudas Tanna vs. State of Gujarat - Though from the Gujarat High Court, this case was leveraged to argue the enforceability of promissory estoppel against revenue claims.

The High Court's legal reasoning hinged on a clear demarcation of the scopes of Sections 115JB and 80-IB:

• Section 115JB (Minimum Alternate Tax): Classified as a charging provision under Chapter XII-B, it imposes a mandatory minimum tax of 7.5% on book profits, ensuring that companies contribute a baseline tax irrespective of their exemptions or concessions.
• Section 80-IB (Tax Exemption for New Industrial Units): Situated within Chapter VI-A, this section provides tax exemptions exclusively based on specific operational criteria of the assessees, such as being located in notified backward areas.

The court posited that these two sections operate in distinct legal realms and are not mutually exclusive. The non obstante clauses embedded within both sections pertain to their respective scopes—quantifying deductions and establishing exemptions—without overriding each other. The principles of promissory estoppel and legitimate expectation were deemed inapplicable because the exemptions under Section 80-IB do not constitute a contractual promise or legal assurance that could be nullified by subsequent statutory provisions.

Furthermore, the court emphasized the non-derogatory interpretation of statutes, asserting that provisions should not be construed in a manner that renders any section ineffective unless explicitly stated. Since Section 115JB does not explicitly exclude the applicability of Section 80-IB, both can coexist, with Section 115JB ensuring that companies pay a minimum tax despite the concessions.

The judgment has several far-reaching implications:

• Clarification on Statutory Hierarchy: Reinforces the principle that charging provisions like Section 115JB have supremacy in ensuring tax compliance, even when other exemptions or concessions are present.
• Non-Applicability of Legal Doctrines: Establishes that doctrines such as promissory estoppel and legitimate expectation do not provide carte blanche exemptions against statutory tax provisions.
• Guidance for Taxpayers: Provides clear guidance to corporate entities that availing tax exemptions under specific sections do not absolve them from complying with mandatory tax liabilities imposed by other provisions like Section 115JB.
• Judicial Interpretation of Non Obstant Clauses: Offers jurisprudential insights into the interpretation of non obstante clauses, emphasizing their contextual application rather than absolute override of other statutory provisions.

Overall, the judgment underscores the judiciary's role in upholding legislative intent and ensuring that tax provisions are applied cohesively to prevent exploitation of tax benefits.

Section 115JB - Minimum Alternate Tax (MAT)

MAT is a provision that ensures companies pay a minimum amount of tax on their book profits, regardless of exemptions, deductions, or incentives that may reduce their taxable income to zero. Under Section 115JB, companies are liable to pay 7.5% of their book profits as tax, ensuring that businesses contribute a baseline tax even if their actual tax liability is nil.

Section 80-IB - Tax Exemption for Specific Industrial Undertakings

This section provides tax exemptions to companies engaged in specific industrial activities located in notified backward areas. The exemption is granted for a certain period, encouraging investment and development in economically lagging regions by reducing the tax burden on qualifying businesses.

Non Obstant Clause

A non obstante clause is a legal provision that allows a particular section of a law to prevail over other conflicting provisions. It ensures that the specific directive within the clause takes precedence, overriding any other contradictory regulations unless explicitly stated otherwise.

Promissory Estoppel

This legal doctrine prevents a party from reneging on a promise that another party has relied upon to their detriment. In the context of taxation, an entity might argue that it was promised certain tax benefits, and therefore, the revenue authorities cannot revoke those benefits retrospectively.

Legitimate Expectation

Legitimate expectation refers to a situation where an individual or entity has a justified expectation of receiving certain benefits or treatment based on previous actions, representations, or established practices of a decision-making authority.