UP Trade Tax – Stainless steel wire not covered within entry (ix) of clause (iv) of S. 14 of CST Act

The language used in entry no. (ix) is plain and unambiguous and that the items which are mentioned there are “tools, alloy and special steel”. By using the words “of any of the above categories” in entry Nos. (ix) would refer to entries (i) to (viii) and it cannot and does not refer to entry no (xv).

However, entry (xvi) of Clause (iv) would be included in entry (xvi) particularly within the expression now therein any of the aforesaid categories. It is a settled principle of law that the words used in the section, rule or notification should not be rendered redundant and should be given effect to: It is also one of the cardinal principles of interpretation of any statue that some meaning must be given to the words used in the section. Besides, in a taxing Act one has to look merely at what is clearly said and there is no room for any intendment. In a taxing statute nothing is to be read in, nothing is to be implied, one can only look fairly at the language used.

M/s. Bansal Wire Industries Ltd. & ANR Vs. State of U.P. & Ors (Supreme Court)

JUDGMENT

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