Strict interpretation of exemption notifications: the assessee must prove applicability and ambiguities favour the revenue. Interpretation of exemption notifications requires strict construction, with the burden on the assessee to prove that facts fall within the exemption. Ambiguities in exemption language are not to be construed for the assessee; such ambiguities are resolved in favour of the revenue. Precedents adopting a beneficiary-oriented liberal reading of exemption clauses have been disapproved and the strict-construction principle has been reaffirmed.
Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
Provisions expressly mentioned in the judgment/order text.
Strict interpretation of exemption notifications: the assessee must prove applicability and ambiguities favour the revenue.
Interpretation of exemption notifications requires strict construction, with the burden on the assessee to prove that facts fall within the exemption. Ambiguities in exemption language are not to be construed for the assessee; such ambiguities are resolved in favour of the revenue. Precedents adopting a beneficiary-oriented liberal reading of exemption clauses have been disapproved and the strict-construction principle has been reaffirmed.
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