Interpretation of exemption notifications in fiscal statutes

The issue of interpretation of exemption notifications has always been a bone of contention which has plagued a plethora of tax payers as well as the Department at large. The said issue was recently examined by the Honourable Supreme Court (‘SC’) in the case of Commissioner of Customs (Import), Mumbai Vs M/s. Dilip Kumar & Co [TS-336-SC2018-CUST] where the question which came up before the SC was on the interpretative rule to be applied while interpreting a tax exemption provision/notification when there is an ambiguity as to its applicability with reference to the entitlement of the assessee or the rate to be applied. This article analyses the SC’s ruling.

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