Full Bench of Supreme Court explained entire law on interpretation of statutes ,relating to ‘purposive interpretation’, ‘strict interpretation’, ‘literal interpretation’, etc explained. Difference in interpretation of statutes vs. exemption notifications explained. Q whether there is doubt or ambiguity in interpretation of a statute or notification benefit of doubt should go to the taxpayer or to the revenue explained. Law on Doctrine of substantial compliance and “intended use” also explained   .Court held as under ;

(1) Exemption notification should be interpreted strictly; the burden of proving applicability would be on the assessee to show that his case comes within the parameters of the exemption clause or exemption notification.

(2) When there is ambiguity in exemption notification which is subject to strict interpretation, the benefit of such ambiguity cannot be claimed by the subject/assessee and it must be interpreted in favour of the revenue.

(3) The ratio in Sun Export Corporation ,Bombay v. Collector of Customs Bombay ( 1997) 6 SCC 564   is not correct and all the decisions which took similar view as in Sun Export Casestands overruled.

The instant civil appeal may now be placed before appropriate Bench for considering the case on merits after obtaining orders from the Hon’ble Chief Justice of India.(     CA NO. 3327 of 2007, dt. 30.07.2018)

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