Statutory interpretation of "issued" under the Wealth-tax Act: Supreme Court reads it as "served" to avoid unjust results.

The word "issued" in section 18(2A) of the Wealth-tax Act is to be read as "served". The Supreme Court affirmed that, in legislative usage, "issued" and "served" may be interchangeable where that construction better fits the statutory purpose and prior judicial interpretation. A narrower meaning of "issued" as merely "sent" was rejected because it would create incongruous and unjust results. The interpretation adopted gives the provision its wider, purpose-consistent effect and aligns the statutory language with settled legal understanding.

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Issues: Whether the word "issued" in section 18(2A) of the Wealth-tax Act is to be construed as meaning "served".

Analysis: The Court affirmed the settled view that, in legislative usage, the expressions "issued" and "served" may be interchangeable. It held that a narrower meaning of "issued" as merely "sent" would produce incongruous and unjust results, and that the wider meaning harmonises with the statutory purpose and prior judicial interpretation.

Conclusion: The word "issued" in section 18(2A) of the Wealth-tax Act means "served".

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