Dismissing the appeal of the revenue , the Court held that , Amount received by an employee from redemption of Stock Appreciation Rights (SARs) can not be assessed as “perquisite” u/s 17(2) (iii) or as “profits of business” u/s 28 (iv) or as “capital gains” ,despite no “cost of acquisition. Circular No 710 dt 24-071995 , was considered . The Court also held that ; the Respondent got the Stock Appreciation Rights (SARs) and, eventually received an amount on account of its redemption prior to 01.04.2000 on which the amendment of Finance Act, 1999 (27 of 1999) came into force. In the absence of any express statutory provision regarding the applicability of such amendment from retrospective effect, we do not find any force in the argument of the Revenue that such amendment came into force retrospectively. It is well established rule of interpretation that taxing provisions shall be construed strictly so that no person who is otherwise not liable to pay tax, be made liable to pay tax. ( CIT v. Infosys Technologies Ltd ( 2008) 297 ITR 167 ( SC),Sumit Bhattacharya v. ACIT ( 2008) 112 ITD 1( SB) ( Mum)( Trib) ( C A. No. 4380/ 4381 of 2018, dt. 24.04.2018)( AY. 1998 -99)