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"Shri Narasimhamurty again relied on certain observations in
CCE v. Parle Exports (P)Ltd. [1989] 1 SCC 345, in support of
strict construction of a provision concerning exemptions. There is
support of judicial opinion to the view that exemptions from
taxation have a tendency to increase the burden on the other un-
exempted class of tax payers and should be construed against the
subject in case of ambiguity. It is an equally well known
principle that a person who claims an exemption has to
establish his case. Indeed, in the very case of Parle Exports (P)
Ltd. relied upon by Shri Narasimhamurthy, it was observed.