https://www.taxtmi.com/caselaws?id=465421 Construction of a tax exemption notification exempting "condoms and all types of oral contraceptive pills" was in issue, specifically whether it extended to an intrauterine contraceptive device. Applying strict literal interpretation, the HC held that ambiguity in exemption provisions must be resolved in favour of the revenue and the assessee must clearly fall within the notification; purposive interpretation based on population-control objectives could not expand the plain words. Consequently, the device was held outside the exemption and remained taxable. The HC further held that each assessment year is a separate cause of action, permitting the assessing authority in a later year to depart from an earlier erroneous allowance of exemption without revisiting past assessments; the revised view was upheld. Appeals were dismissed in favour of the revenue. en-us Wed, 13 Sep 2023 00:00:00 +0530 Mon, 22 Dec 2025 15:18:06 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=465421 Construction of a tax exemption notification exempting "condoms and all types of oral contraceptive pills" was in issue, specifically whether it extended to an intrauterine contraceptive device. Applying strict literal interpretation, the HC held that ambiguity in exemption provisions must be resolved in favour of the revenue and the assessee must clearly fall within the notification; purposive interpretation based on population-control objectives could not expand the plain words. Consequently, the device was held outside the exemption and remained taxable. The HC further held that each assessment year is a separate cause of action, permitting the assessing authority in a later year to depart from an earlier erroneous allowance of exemption without revisiting past assessments; the revised view was upheld. Appeals were dismissed in favour of the revenue. Case-Laws VAT / Sales Tax Wed, 13 Sep 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=465421