A taxing statute, as is well-known, must be construed strictly. In Sneh
Enterprises v. Commissioner of Customs [2006] 7 SCC 714, it was held :
"While dealing with a taxing provision, the principle of 'Strict Interpre-
tation should be applied. The Court shall not interpret the statutory
provision in such a manner which would create an additional fiscal burden on
a person. It would never be done by invoking the provisions of another Act,
which are not attracted. It is also trite that while two interpretations are
possible, the Court ordinarily would interpret the provisions in favour of a
taxpayer and against the Revenue."
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