The Assistant Commissioner, ... vs M/S. Velliappa Textiles Ltd. & Anr

The Supreme Court addressed the prosecution of a limited company and its Managing Director under Sections 276C, 277, and 278 read with Section 278B of the Income Tax Act. The Court held that while the sanction under Section 279 was valid, a company, as a juristic person, cannot be subjected to mandatory imprisonment under Sections 276C and 277. The judgment emphasized that penal statutes must be strictly construed, and the court cannot fill legislative gaps, reinforcing the principle that the law must be applied as written without judicial overreach.