Strict construction: taxing statutes require clear language, and ambiguities are resolved in favour of the taxpayer.

Strict construction requires that taxes and similar fiscal burdens be imposed only by clear, unambiguous statutory language; ambiguities are resolved in favour of the taxpayer and equitable considerations have no place in construing taxing statutes. While strict construction limits judicial implication or equitable enlargement of charges, it is distinct from rigid literalism and should not produce absurd results; courts may, where appropriate, have regard to legislative object so that interpretation does not defeat manifest intent.

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