Okay, I'm ready to provide a legal analysis of Section 112 of the Income Tax Act, 1961, following your specified format. However, the case title you provided, "Section 112 in The Income Tax Act, 1961" and the court "Union of India - Section" is not a valid case. Section 112 is a provision within the Income Tax Act, not a case itself. The "Union of India" is a common party in cases involving the government, but "Section" is not a court.

To provide a meaningful summary, I need an actual case citation or name that involves a dispute regarding Section 112 of the Income Tax Act.

Assuming a hypothetical case concerning Section 112, dealing with taxation of long-term capital gains, here's an example of how I would structure the analysis:

Short Summary

This hypothetical case concerns the interpretation of Section 112 of the Income Tax Act, 1961, specifically regarding the applicable tax rate on long-term capital gains arising from the sale of listed securities. The court held that the assessee was liable to pay tax at the rate specified in Section 112, rejecting the argument for a lower rate based on a specific interpretation of the provision.

Facts

Mr. Sharma, the assessee, sold listed shares held for more than 12 months, resulting in a long-term capital gain. He computed his tax liability based on what he believed was a concessional rate, arguing that a specific clause within Section 112 allowed for this. The Income Tax Department assessed him at a higher rate, contending that his interpretation was incorrect and the standard rate for long-term capital gains applied.

Issues

The primary issue was the correct interpretation of Section 112 of the Income Tax Act, 1961, specifically whether the assessee was entitled to a lower tax rate on long-term capital gains from the sale of listed securities based on his interpretation of the provision.

Petitioner's Arguments (Mr. Sharma)

Mr. Sharma argued that a particular clause in Section 112, when read in conjunction with other sections of the Act, permitted him to pay tax at a lower rate than the standard rate applicable to long-term capital gains. He presented expert opinions supporting his interpretation and cited previous rulings that, according to him, supported his position.

Respondent's Arguments (Income Tax Department)

The Income Tax Department argued that Section 112 should be interpreted literally and that the standard rate for long-term capital gains applied to the assessee's income. They contended that Mr. Sharma's interpretation was strained and not supported by the overall scheme of the Income Tax Act. They cited circulars and notifications issued by the Central Board of Direct Taxes (CBDT) to support their position.

Court's Reasoning

The court analyzed the language of Section 112, giving due consideration to the context of the entire Income Tax Act. The court emphasized the principle of literal interpretation, stating that the plain meaning of the words should be followed unless it leads to absurdity. The court found that Mr. Sharma's interpretation was not supported by the clear language of the section and that the CBDT circulars clarified the intended application of the provision. The court also distinguished the previous rulings cited by Mr. Sharma, finding them factually different and not applicable to the present case.

Conclusion

The court ruled in favor of the Income Tax Department. The assessee, Mr. Sharma, was held liable to pay tax on his long-term capital gains at the rate specified by the Income Tax Department. His petition was dismissed.

Important Note: This is a hypothetical example. To provide an accurate summary, please provide a valid case citation or name.