JUDGMENT M.F. Saldanha, J.—We have heard the appellant's learned counsel and learned senior counsel who represents the respondents. The main point raised by the appellant's learned counsel was that admittedly, if one were to look at the sequence of the calendar of events, in other words, the strict dates when the additional or enhanced compensation was admittedly received by the assessee at a point of time when the provisions of Section 54E(3) were no longer on the statute book in so far as the same were omitted by the Finance Act, 1987, with effect from April 1, 1988. The appellant's learned counsel submits that irrespective of what may be possible in other situations, there is a clear error in the present instance in affording the benefit to the assessee under the provision that was no longer on the statute book as on the date when the additional compensation was physically received. Prima facie, the submission appeared absolutely invincible because going by first principles, the contention raised by learned counsel would be totally justified and consequently it was his submission that this court would need to interfere with the order passed by the Tribunal. 2. Pausing here for a moment, we do need to express more than a level of displeasure with regard to the quality of the order passed by the Tribunal in this case which shows not only total non-application of mind but also total and complete disregard for the elementary principles that govern the manner in which a responsible forum is required to decide a case of some consequence. Mr. Indrakumar would naturally be severely handicapped while presenting an appeal against such an order in so far as the order is virtually silent on every relevant aspect. Short of a bald narration of the sequence of events and the issues involving the order says virtually nothing and the first reaction of this court was to straightaway quash the order and remand the case for a redecision. 3. It was at this point that learned senior counsel who represents the respondents submitted that there is an equally valid principle of law which this High Court has been upholding, namely, that a remand would be contra-indicated unless it is demonstrated that some useful purpose would be served through such a remand. Mr. 3. It was at this point that learned senior counsel who represents the respondents submitted that there is an equally valid principle of law which this High Court has been upholding, namely, that a remand would be contra-indicated unless it is demonstrated that some useful purpose would be served through such a remand. Mr. Sarangan did not seek to defend the quality of the Tribunal's order but the submission canvassed by him was slightly different in so far as he contended that there are two reported decisions of the Andhra Pradesh High Court wherein all the relevant provisions that are germane to the decision in the present case have been very carefully analysed and where the High Court has again based the quality of its interpretation on the guidelines laid down by the Supreme Court in one of the very important salutary judgments to which we will have occasion to make a reference, and his submission was therefore that if these are the principles of law that apply to the decision, on the present set of facts, a remand would not only be counter-productive but would be against the interests of justice because his clients would be dragged through one more round of litigation which would not serve any purpose. Mr. Sarangan points us that the law was virtually concluded by this decision and in the face of this position it is certainly open to the High Court to hear learned counsel at this stage itself and record a verdict instead of relegating the proceeding b.ack to the Tribunal. The main reason why we are upholding Mr. Sarangan's submission is because it has been not only the sad but disastrous experience of this court, which we have had occasion to refer to in an earlier reported decision, that despite the High Court virtually setting out guidelines indicating where the lower authority has gone wrong and despite the Department having the obvious benefit of their own learned counsel pointing out to the authority as to what was the error on the previous occasion, this court has found that in the majority of cases that are remanded a kind of ego problem comes up in so far as the feathers get ruffled and an even more foolish order emerges. Ultimately, in order to put a full stop to the litigation going in circles on the second or third occasion, purely, out of a sense of fatigue, it is the High Court which ultimately decides the issue and sets it at rest. There is, therefore, much justification in the objections that have been raised by Mr. Sarangan that regardless of the fact that the Tribunal's orders may be absolutely unsatisfactory in the present circumstances no remand is warranted. 4. Going back to Mr. Indrakumar's submissions he did deal with the two decisions of the Division Bench of the Andhra Pradesh High Court the first of them reported in S. Gopal Reddy Vs. Commissioner of Income Tax, (1990) 181 ITR 378 AP , which in turn was followed in the later decision reported in Commissioner of Income Tax Vs. Roda Mistry, (1998) 231 ITR 12 AP . What Mr. Indrakumar submitted was that those principles would undoubtedly hold good provided according to him the sequence of events is all confined to the period between April 1, 1978, and April 1, 1988, which was the ten year gap when the provisions of the section were on the statute book. He vehemently contended that the situation gets violently altered if it can be demonstrated that the enhanced compensation was received at a point of time after the deletion has taken place. Undoubtedly, what learned counsel was submitting was that since we are really concerned with the consequence of the investment made, the benefit that accrues to the assessee would not arise in view of the time factor that is involved. As indicated by us earlier, the argument does appear to be profound and the principles on which it is based are undoubtedly sound. There is, however, another angle to the whole controversy which is precisely what Mr. Sarangan, learned senior counsel, who represents the respondents, emphasised and what really emerges from the two decisions that have been referred to by us. There is, however, another angle to the whole controversy which is precisely what Mr. Sarangan, learned senior counsel, who represents the respondents, emphasised and what really emerges from the two decisions that have been referred to by us. What the Division Bench was at pains to point out was that while construing beneficial provisions that are specifically put on the statute book for a specific purpose, namely, to give to the assessee certain benefit which the law confers because of the fact that otherwise, in situations such as a compulsory acquisition where the assessee is left with a large capital amount if the normal principles of taxation were to apply, a greater part of that receipt would virtually be confiscated. It is for this reason that the Division Bench very clearly pointed out that it is necessary to harmoniously construe the provisions of Sections 54E(3), 155(7A) and 155(10B) because it is only through harmonious application of the law that the effective purpose of the law can be achieved. This is really the crux of the matter, but what we also need to point out is that the courts have been repeatedly emphasising the fact that the interpretation should not be technical and more importantly the result of interpretation should not give rise to absurdity. In the present instance, what we need to also clarify is that if the time factor concept were to be mechanically applied or as the appellant's learned counsel submits, if it were to be strictly applied, it would lead to an incongruous situation whereby for no fault of the assessee, the compensation received at one point of time would qualify for the benefit whereas the remainder of it would not qualify for the benefit and there is virtually no logic or justification or reason that could support such a situation. We go a stage further because it would be incorrect to dissect the compensation into different claims and to disqualify that part of it which had been received after a certain period of time for no fault of the assessees, mainly because the enhancement proceedings took time and it does not mean that because of the operation of the law the assessee is going to be punished for it. The only rational way of looking at the issue would be to view it from a rational angle or in other words to hold that when the compensation is enhanced that it notionally dates back to the original receipt which in turn gets modified or multiplied. 5. We need to reiterate here that we have been guided by certain well defined principles relating to the interpretation of statutes and in this context, we need to reiterate what the Supreme Court had laid down in the decision reported in CIT Vs. J. H. Gotla wherein the Supreme Court observed as follows (headnote) ; "If a strict and literal construction of the statute leads to an absurd result, i.e., a result not intended to be sub served by the object of the legislation ascertained from the scheme of the legislation, then, if another construction is possible apart from the strict literal construction, then, that construction should be preferred to the strict literal construction. Where the plain literal interpretation of a statutory provision produces a manifestly unjust result which could never have been intended by the Legislature, the court might modify the language used by the Legislature so as to achieve the intention of the Legislature and produce a rational result." 6. What is even more significant is the observation of the court in this case wherein it was observed (headnote) : "Though equity and taxation are often strangers, attempts should be made that these do not remain always so and if a construction results in equity rather than in injustice, then such construction should be preferred to the literal construction." 7. In a subsequent decision reported in Saroj Aggarwal Vs. Commissioner of Income Tax, U.P., AIR 1986 SC 376 , again the Supreme Court observed as follows (headnote) : "Facts should be viewed in natural perspective, having regard to the compulsion of the circumstances of a case. Where it is possible to draw two inferences from the facts and where there is no evidence of any dishonest or improper motive on the part of the assessee, it would be just and equitable to draw such inference in such a manner that would lead to equity and justice. Too hypertechnical or legalistic approach should be avoided in looking at a provision which must be equitably interpreted and justly administered." 8. Too hypertechnical or legalistic approach should be avoided in looking at a provision which must be equitably interpreted and justly administered." 8. We are here concerned with a situation in which, in our considered view, the law as expounded by the Division Bench of the Andhra Pradesh High Court needs to be applied to the facts of the present case and on doing so, we have no hesitation in holding that the assessee does qualify for the benefit. It is not only unfortunate but virtually tragic that we cannot confirm the order passed by the Tribunal and therefore strange as it may seem, while we are required to set aside that order we are still required to uphold the benefit to the assessee for the reasons set out in this judgment. Consequently, on the grounds indicated in the preceding sentences though the appeal technically succeeds it is only a paper decree for the Department. 9. In the circumstances of the case, there shall be no order as to costs.