Statutory interpretation of "fails to submit a return" rejected a reading-in of "without reasonable cause" under sales tax law.

The phrase "fails to submit a return" in Section 15(a) of the General Sales Tax Act was not construed as meaning "fails without reasonable cause". The Madras HC noted that reading words into a statute is justified only where the plain meaning leads to anomalous results or is clearly inconsistent with the legislative scheme. As the Court found no such inconsistency on the facts, it declined to cut down the natural meaning of the provision. The conviction was therefore upheld.

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Issues: Whether the words "fails to submit a return" in Section 15(a) of the General Sales Tax Act should be read as "fails without reasonable cause".

Analysis: The petitioners contended that, in light of the scheme and purpose of the Act, the provision should be cut down to cover only a failure without reasonable cause. The Court held that a statute may be read down only where the natural meaning produces strangely anomalous results or is clearly inconsistent with the legislative scheme. On the facts, the Court was not satisfied that giving the words their natural meaning would produce such a result, and therefore found no basis to add words to the section.

Conclusion: The phrase in Section 15(a) was not read as containing the words "without reasonable cause", and the conviction was upheld.

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