Important Legal Definitions

The canon of fiscal interpretation establishing that there is no equity about a tax; the subject cannot be taxed unless the words of the charging section unambiguously impose the tax liability, without importing equitable considerations.

In Cape Brandy Syndicate v. IRC (consistently reaffirmed by the Supreme Court, as in Commissioner of Customs (Import) v. Dilip Kumar & Co.), it was held: "In a taxing Act one has to look merely at what is clearly said. There is no room for any intendment."