implied and there is no room for any
intendment. (See: Cape Brandy Syndicate Vs. Inland
Revenue Commissioners4 and Ajmera Housing Corporation
& Anr. Vs. Commissioner
intendment. There is no
equity about a tax. (See: Cape Brandy Syndicate Vs. Inland Revenue
Commissioners7 and Federation of A.P. Chambers of Commerce
court as to what is just or
expedient. In Cape Brandy Syndicate v. IRC (1921) 1 KB
64 it was said that one must look
following passage
from the opinion of Late Rowlatt, J. in Cape Brandy Syndicate Vs. Inland
Revenue Commissioners5 has become the locus classicus and has been
Commissioner of Wealth-tax. , (1997) 224 ITR 672. In Cape Brandy Syndicate v. IRC, (1921) 1 KB 64, it was said that
implied. One can only look fairly at the language used. "(Cape Brandy Syndicate v. IRC [1921] 1 KB 64).
8. We find no merit
differentiation. In the immortal words of Rowla(SIC), J. in Cape Brandy Syndicate v. I.R.C. (1921) 1 KB 64: "In a taming
rule of interpretation in the case of a fiscal statute, in Cape Brandy Syndicate Vs. Inland Revenue Commissioners, (1921) 1 KB 64 at 71, Rowlatt
rule of interpretation in the case of a fiscal statute, in Cape Brandy Syndicate v. IRC (1921) 1 KB 64 at p. 71, Rowlatt