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24. The Hon'ble Supreme Court has also often made reference to a well-known passage of Rowlatt, J. in Cape Brandy Syndicate Vs. Commissioners of Inland Revenue, (1921) 1 KB 64 in several cases. In CIT Vs. Yokogawa India Ltd., (2017) 2 SCC 1 : 2016 SCC OnLine SC 1491, the Honourable Supreme Court observed as under:-

8. The cardinal principles of interpretation of taxing statutes centres around the opinion of Rowlatt, J. In Cape Brandy Syndicate v. Inland Revenue Commissioners [Cape Brandy Syndicate v. Inland Revenue Commissioners, (1921) 1 KB 64] which has virtually become the locus classicus [ A classical passage : a standard passage important for the elucidation of a word or subject (See: Webster's Third New International Dictionary, Vol. II, p.

1329).] . The above would dispense with the necessity of any further elaboration of the subject notwithstanding the numerous precedents available inasmuch as the evolution of all such principles are within the four corners of the following opinion of Rowlatt, J.: (Cape Brandy case [Cape Brandy Syndicate v. Inland Revenue Commissioners, (1921) 1 KB 64] , KB p. 71) ______________ https://www.mhc.tn.gov.in/judis/ Page No 12 of 26 W.P.Nos.8255 & 8256 of 2015 “… in a taxing Act one has to look merely at what is clearly said. There is no room for any intendment. There is no equity about a tax. There is no presumption as to a tax. Nothing is to be read in, nothing is to be implied. One can only look fairly at the language used.”