In a taxing Act, one has to  look merely at what is clearly said. There is no room for any intendment. There  is no equity about a tax . There is no  presumption as to a tax .Nothing to be read in . nothing is to be implied .One can only look fairly at the language used .A person invoking an exception or an exemption provision to relieve him of the tax liability must establish clearly that he is covered by the provision  ( CA NOS.792-793 OF 2014, dt. 02.07.2018)( AY. 2003 -04 , 2004 -05)