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<h1>Interpreting 'Issued' vs. 'Served' in Wealth-tax Act: Supreme Court Decision</h1> The Supreme Court dismissed the petition as the word 'issued' in section 18(2A) of the Wealth-tax Act was interpreted to mean 'served,' based on previous ... Meaning of 'issued' in taxation statutes - service of notice - judicial precedent interpreting statutory wording - statutory interpretation: 'issued' to include 'served'Meaning of 'issued' in taxation statutes - service of notice - statutory interpretation: 'issued' to include 'served' - 'issued' in section 18(2A) of the Wealth-tax Act is to be read to mean 'served' - HELD THAT: - The Court accepted the High Court's conclusion that the expression 'issued' in the provision must be given the wider meaning of 'served' rather than a narrow sense of merely 'sent'. The conclusion is supported by earlier judicial decisions, including Banarsi Debi v. Income-tax Officer, Calcutta, where it was observed that 'issued' and 'served' are used interchangeably in legislative practice and that 'issued' had been judicially interpreted to mean 'served.' The reasoning noted the purpose of the term and the dictionary meaning, which encompasses both the sending of notices and their service; a narrow construction would lead to incongruous and unjust results. On this basis the Court dismissed the petition seeking re-examination of that point.High Court's interpretation adopted; 'issued' in section 18(2A) construed to include 'served' and the petition dismissed.Final Conclusion: The Supreme Court upheld the High Court's construction that 'issued' in section 18(2A) of the Wealth-tax Act includes 'served,' relying on prior judicial interpretation, and dismissed the petition. The Supreme Court dismissed the petition as the word 'issued' in section 18(2A) of the Wealth-tax Act was interpreted to mean 'served,' based on previous court decisions. The court found that any other interpretation would lead to unjust results. The petition was dismissed.
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