Exemption notification to be interpreted strictly
The Constitutional Bench (five-judge bench) of the Supreme Court held that:
(1) exemption from tax guidance is to be interpreted strictly and the burden to prove its applicability is on the taxpayer;
(2) any ambiguity in the exemption guidance must be interpreted in favour of the tax department; and
(3) prior decisions to the contrary are overturned.
The case is: Dilip Kumar and Company & Ors. Read an August 2018 report [PDF 700 KB] of KEPMG