It is a fundamental principle of law that a receipt under the Act must be made taxable before it can be treated as income .Courts cannot not construe the law in such a way that brings an individual who otherwise is not liable to pay tax ,with in the meaning of the income- tax Act , 1961 to pay tax .In the absence of any such specific provision , if an individual is subject to pay tax , it would amount to the violation of his Constitutional right. Taxing provisions must be construed strictly so that no person who is otherwise not liable to pay tax , be made liable to pay tax .  CBDT circulars  cannot be used to introduce new tax provision in statute  which other wise absent .