Bajaj Tempo Ltd. Bombay vs Commissioner Of Income Tax,Bombay ... on 24 April, 1992
Mr. Bharukha further submitted that in taxing statutes, provision of concessional
rate of tax should be liberally construed and in respect of the above submission, he
cited the judgment of this Court in Commissioner of Sales Tax vs. Industrial Coal
Enterprises (Supra) and in the case of Bajaj Tempo Ltd., Bombay vs.
Commissioner of Income Tax, Bombay City-III, Bombay (Supra). We are unable to
countenance the above submission. In our view, the provisions of exemption clause
should be strictly construed and if the condition under which the exemption was granted
stood change on account of any subsequent event the exemption would not operate.