Gursahai Saigal v. CIT
48 ITR 1Supreme Court of India1963#952 most cited
What is Gursahai Saigal v. CIT authority for?
The rule of strict construction applies to a taxing provision that creates a charge for tax, but machinery provisions for making assessments are interpreted liberally. This distinction ensures that while the tax burden is clearly established, procedural aspects are construed to facilitate tax collection.
112
judgments rely on this decision, according to BharatTax’s citation analysis of 367,181 Indian tax judgments — from 2018 to 2025.
Also referred to as
Gursahai Saigal v. CIT · 48 ITR 1 · SC 1963 · interpretation of taxing statutes · charging provision · machinery provision · strict construction · liberal interpretation · assessment procedure · income tax law