Law:

Section:

(a) Interpretation of statutes----Taxing statute--Tax exemptions--Principle--In taxing statute one has to look at what is clearly said; there is no room for any intendment; there is no equity about a tax, nothing is to be read and nothing is to be implied--Where a provision in taxing statute can be reasonably interpreted in two ways, interpretation which is favourable to assessee has to be accepted--If two views are possible, the one which favours the assessee has to be accepted--Rules regarding exemption under taxing statute have to be established by precedents and exemption under taxing statute must be strictly construed--Grants of tax exemptions are given a rigid interpretation against assertions of taxpayer and in favour of taxing power--Basis for such rule is the same as that supporting a rule of strict construction of positive revenue laws that burden of taxation should be distributed equally and fairly among members of society--When an exempting provision is susceptible to two interpretations, the one going against tax payer is preferred. Commissioner of Income Tax Khanpur v. Upper Doab Sugar Mills 1978 All L-128; Pakistan Textile Mill Owners Association, Karachi and 02 others v. Administrator of Karachi and 02 others PLD 1963 SC 137; Islamabad Electric Supply Company Limited v. Deputy Commissioner Inland Revenue Audit-II, LTU, Islamabad 2016 PTD 2685; CIT v. Naga Hills Tea Co. Ltd AIR 1973 SC 2524; Sun Export Corporation v. Collector of Customs (1997) 6 SCC 564; Sutherland on Statutory Construction (Third Edition Vol.3); Collector of Custom FBR and another v. Messrs Fitter Pakistan (Pvt.) Ltd. 2020 SCMR 1157; Oxford University Press v. Commissioner of Income Tax, Companies Zone-I, Karachi and others 2019 SCMR 235; Pakistan Machine Tool Factory (Pvt.) Ltd., Karachi v. Commissioner of Sales, Central, Zone-B, Karachi 2006 SCMR 1577 and Messrs Bisvil Spinners Ltd. v. Superintendent Central Excise and Land Customs Circle Sheikhupura and another PLD 1988 SC 370 rel. (b) Income Tax Ordinance (XLIX of 2001)---S. S3--Constitution of Pakistan, Arts. 199 247 [as amended by 25th Constitutional Amendment]--Notification SRO 1213(I)/2018 dated…

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