Important Legal Definitions

A settled rule of fiscal interpretation: an assessee claiming the benefit of an exemption notification must prove they fall strictly within the eligibility criteria; once eligibility is established, the notification is construed liberally.

In Commissioner of Customs (Import), Mumbai v. Dilip Kumar & Co., a five-judge Constitution Bench held that any ambiguity in an exemption notification must be resolved in favor of the Revenue and against the assessee.