A taxing statue should not be interpreted in such a manner that its effect would be to cast a burden twice over for the payment of tax on the taxpayer unless the language of the statute is so compelling that the Court has no alternative than to accept it. In a case of reasonable doubt , the construction most beneficial to the tax payer is to be adopted .( Referred, Laxmipat Singhania v. CIT ( 1969) 72 ITR 291 (SC) Jain Brothers v. UOI ( 1970) 77 ITR 107 (SC)
Mahaveer Kumar Jain v. CIT ( 2018) 404 ITR 738/ 165 DTR 113/ 302 CTR 1/ 255 Taxman 161 (SC) , www.itatonline.org
Interpretation of taxing statues- Rule against double taxation