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V.V. Iyer Of Bombay vs Jasjit Singh, Collector Of Customs And ... on 22 September, 1972

36. The respondents have called in aid the principle enunciated in the decision of V.V. Iyer v. Jasjit Singh (Supra) and Collector of Customs, Bombay v. Swastik Woollen (P) Ltd, to the effect that where two views are possible and the authorities adopt one of such views which cannot be termed to be unreasonable, the authorities' finding cannot be interfered with by the High Court. This principle appears to be in direct conflict with the well-known norm of construction that in the event of ambiguity in a fiscal statute the construction beneficial to the assessee should be adopted.
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