I.T.C. Ltd. v. CCE

7 SCC 591Supreme Court of India2004#2115 most cited

What is I.T.C. Ltd. v. CCE authority for?

The Supreme Court holds that words in a statute, particularly a fiscal one, must be construed strictly according to their ordinary and natural meaning, irrespective of the provision's object. If the statutory language is unambiguous, it must be given effect, as the legislature is deemed to intend and mean what it says, only resorting to legislative intent if there is ambiguity.

55

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2017 to 2025.

Also referred to as

I.T.C. Ltd. v. CCE · statutory construction · fiscal statute interpretation · plain meaning rule · literal rule of interpretation · unambiguous statutory language · legislative intent · Section 56(2)(viii) · Section 57(iv) · Income Tax Act 1961

Sections most often in play

Section 10(37)Section 56(2)(viii)Section 145ASection 1894Section 57(iv)Section 142(1)Section 143(2)Section 1961

Issues it is cited on

section 2(viii)section 56(viii)section 45(5)(c)section 155(16)section 23(1a)section 45(5)(b)section 104section 145b(1)section 194lakeyman insurancesection 160section 23(2)

Judgments citing I.T.C. Ltd. v. CCE

RANJIT SINGH,PANCHKULA vs. DEPUTY DIRECTOR, CPC DEPARTMENT

ITA 992/CHANDI/2025[2023-24]Status: DisposedITAT Chandigarh11 Nov 2025AY 2023-24

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

For Appellant: Shri Suraj Bhan Nain, AdvocateFor Respondent: Shri Manav Bansal, CIT, DR

…i.e. the language of sections 56(2)(viii) and 57(iv) of the 1961 Act is plain, simple and unambiguous. There is no scope of taking outside aid for giving an interpretation to newly inserted sub-sections and clauses. Supreme Court in I.T.C. Ltd. v. CCE [2004] 7 SCC 591 held as under: "23. ........These decisions exemplify the general rule of statutory construction that words have to be construed strictly according to their ordinary and natural meaning, particularly when the statute is a fiscal one irrespective of the object with which the provision was introduced. Of course if there is ambiguity in the statutory…

LABH SINGH,PANCHKULA vs. INCOME TAX OFFICER, WARD NO 2,, PANCHKULA

ITA 725/CHANDI/2025[2015-16]Status: DisposedITAT Chandigarh11 Nov 2025AY 2015-16
For Appellant: \nShri Suraj Bhan Nain, AdvocateFor Respondent: \nShri Manav Bansal, CIT, DR

…. the language\nof sections 56(2) (viii) and 57(iv) of the 1961 Act is plain, simple and unambiguous.\nThere is no scope of taking outside aid for giving an interpretation to newly inserted\nsub-sections and clauses. Supreme Court in I.T.C. Ltd. v. CCE [2004] 7 SCC 591 held as\nunder:\n\"23. ........These decisions exemplify the general rule of statutory construction that\nwords have to be construed strictly according to their ordinary and natural meaning,\nparticularly when the statute is a fiscal one irrespective of the object with which the\nprovision was introduced. Of course if there is ambiguity in the stat…

BHUPINDER SINGH,AMBALA vs. INCOME TAX OFFICER, W-1, AMBALA, AMBALA

ITA 528/CHANDI/2025[2014-15]Status: DisposedITAT Chandigarh11 Nov 2025AY 2014-15
For Respondent: \nShri Suraj Bhan Nain, Advocate

…. the language\nof sections 56(2) (viii) and 57(iv) of the 1961 Act is plain, simple and unambiguous.\nThere is no scope of taking outside aid for giving an interpretation to newly inserted\nsub-sections and clauses. Supreme Court in I.T.C. Ltd. v. CCE [2004] 7 SCC 591 held as\nunder:\n\"23. ........These decisions exemplify the general rule of statutory construction that\nwords have to be construed strictly according to their ordinary and natural meaning,\nparticularly when the statute is a fiscal one irrespective of the object with which the\nprovision was introduced. Of course if there is ambiguity in the stat…

SH. HAKAM SINGH,PATIALA vs. INCOME TAX OFFICER, WARD-4, PATIALA

ITA 486/CHANDI/2025[2020-21]Status: DisposedITAT Chandigarh11 Nov 2025AY 2020-21

…. the language\nof sections 56(2) (viii) and 57(iv) of the 1961 Act is plain, simple and unambiguous.\nThere is no scope of taking outside aid for giving an interpretation to newly inserted\nsub-sections and clauses. Supreme Court in I.T.C. Ltd. v. CCE [2004] 7 SCC 591 held as\nunder:\n\"23. ........These decisions exemplify the general rule of statutory construction that\nwords have to be construed strictly according to their ordinary and natural meaning,\nparticularly when the statute is a fiscal one irrespective of the object with which the\nprovision was introduced. Of course if there is ambiguity in the stat…

BALBIR SINGH,SIRSA, HARYANA vs. ITO, WARD-1, SIRSA, SIRSA, HARYANA

ITA 483/CHANDI/2025[2018-19]Status: DisposedITAT Chandigarh11 Nov 2025AY 2018-19
For Respondent: \nShri Suraj Bhan Nain, Advocate

…. the language\nof sections 56(2) (viii) and 57(iv) of the 1961 Act is plain, simple and unambiguous.\nThere is no scope of taking outside aid for giving an interpretation to newly inserted\nsub-sections and clauses. Supreme Court in I.T.C. Ltd. v. CCE [2004] 7 SCC 591 held as\nunder:\n\"23. ........These decisions exemplify the general rule of statutory construction that\nwords have to be construed strictly according to their ordinary and natural meaning,\nparticularly when the statute is a fiscal one irrespective of the object with which the\nprovision was introduced. Of course if there is ambiguity in the stat…

BISHAN CHAND,CHANDIGARH vs. INCOME TAX OFFICER, WARD 5 (5), CHANDIGARH, CHANDIGARH

ITA 458/CHANDI/2025[2018-19]Status: DisposedITAT Chandigarh11 Nov 2025AY 2018-19
For Respondent: \nShri Suraj Bhan Nain, Advocate

…. the language\nof sections 56(2) (viii) and 57(iv) of the 1961 Act is plain, simple and unambiguous.\nThere is no scope of taking outside aid for giving an interpretation to newly inserted\nsub-sections and clauses. Supreme Court in I.T.C. Ltd. v. CCE [2004] 7 SCC 591 held as\nunder:\n\"23. ........These decisions exemplify the general rule of statutory construction that\nwords have to be construed strictly according to their ordinary and natural meaning,\nparticularly when the statute is a fiscal one irrespective of the object with which the\nprovision was introduced. Of course if there is ambiguity in the stat…

SAT PAL,CHANDIGARH vs. INCOME TAX OFFICER, WARD 5(5), , CHANDIGARH

ITA 243/CHANDI/2025[2018-19]Status: DisposedITAT Chandigarh11 Nov 2025AY 2018-19

…. the language\nof sections 56(2) (viii) and 57(iv) of the 1961 Act is plain, simple and unambiguous.\nThere is no scope of taking outside aid for giving an interpretation to newly inserted\nsub-sections and clauses. Supreme Court in I.T.C. Ltd. v. CCE [2004] 7 SCC 591 held as\nunder:\n\"23. ........These decisions exemplify the general rule of statutory construction that\nwords have to be construed strictly according to their ordinary and natural meaning,\nparticularly when the statute is a fiscal one irrespective of the object with which the\nprovision was introduced. Of course if there is ambiguity in the stat…

NARENDER KAUR,KURUKSHETRA, HARYANA vs. INCOME TAX OFFICER WARD-1 , KURUKSHETRA

ITA 165/CHANDI/2025[2018-19]Status: DisposedITAT Chandigarh11 Nov 2025AY 2018-19
For Respondent: \nShri Suraj Bhan Nain, Advocate

…. the language\nof sections 56(2) (viii) and 57(iv) of the 1961 Act is plain, simple and unambiguous.\nThere is no scope of taking outside aid for giving an interpretation to newly inserted\nsub-sections and clauses. Supreme Court in I.T.C. Ltd. v. CCE [2004] 7 SCC 591 held as\nunder:\n\"23. ........These decisions exemplify the general rule of statutory construction that\nwords have to be construed strictly according to their ordinary and natural meaning,\nparticularly when the statute is a fiscal one irrespective of the object with which the\nprovision was introduced. Of course if there is ambiguity in the stat…

BALVINDER SINGH,FATEHABAD vs. ITO WARD-1, FATEHABAD

ITA 153/CHANDI/2025[2013-14]Status: DisposedITAT Chandigarh11 Nov 2025AY 2013-14

…. the language\nof sections 56(2) (viii) and 57(iv) of the 1961 Act is plain, simple and unambiguous.\nThere is no scope of taking outside aid for giving an interpretation to newly inserted\nsub-sections and clauses. Supreme Court in I.T.C. Ltd. v. CCE [2004] 7 SCC 591 held as\nunder:\n\"23. ........These decisions exemplify the general rule of statutory construction that\nwords have to be construed strictly according to their ordinary and natural meaning,\nparticularly when the statute is a fiscal one irrespective of the object with which the\nprovision was introduced. Of course if there is ambiguity in the stat…

GURDEEP SINGH HUF,CHANDIGARH vs. ITO, WARD 5(5), CHANDIGARH

ITA 1153/CHANDI/2025[2020-21]Status: DisposedITAT Chandigarh11 Nov 2025AY 2020-21

…. the language\nof sections 56(2) (viii) and 57(iv) of the 1961 Act is plain, simple and unambiguous.\nThere is no scope of taking outside aid for giving an interpretation to newly inserted\nsub-sections and clauses. Supreme Court in I.T.C. Ltd. v. CCE [2004] 7 SCC 591 held as\nunder:\n\"23. ........These decisions exemplify the general rule of statutory construction that\nwords have to be construed strictly according to their ordinary and natural meaning,\nparticularly when the statute is a fiscal one irrespective of the object with which the\nprovision was introduced. Of course if there is ambiguity in the stat…

JARNAIL SINGH,VILLAGE BHAGWANPUR, KALKA vs. ITO, WARD-2, PANCHKULA

ITA 1025/CHANDI/2025[2015-16]Status: DisposedITAT Chandigarh11 Nov 2025AY 2015-16

…. the language\nof sections 56(2) (viii) and 57(iv) of the 1961 Act is plain, simple and unambiguous.\nThere is no scope of taking outside aid for giving an interpretation to newly inserted\nsub-sections and clauses. Supreme Court in I.T.C. Ltd. v. CCE [2004] 7 SCC 591 held as\nunder:\n\"23. ........These decisions exemplify the general rule of statutory construction that\nwords have to be construed strictly according to their ordinary and natural meaning,\nparticularly when the statute is a fiscal one irrespective of the object with which the\nprovision was introduced. Of course if there is ambiguity in the stat…

BALJEET KAUR,NADI MOHALLA AMBALA CITY vs. ITO WARD 1, AMBALA, AMBALA

ITA 92/CHANDI/2024[2014-15]Status: DisposedITAT Chandigarh11 Nov 2025AY 2014-15

…. the language\nof sections 56(2) (viii) and 57(iv) of the 1961 Act is plain, simple and unambiguous.\nThere is no scope of taking outside aid for giving an interpretation to newly inserted\nsub-sections and clauses. Supreme Court in I.T.C. Ltd. v. CCE [2004] 7 SCC 591 held as\nunder:\n\"23. ........These decisions exemplify the general rule of statutory construction that\nwords have to be construed strictly according to their ordinary and natural meaning,\nparticularly when the statute is a fiscal one irrespective of the object with which the\nprovision was introduced. Of course if there is ambiguity in the stat…

ARJESH KUMAR,PATIALA vs. ITO NATIONAL E-ASSESSMENT CENTRE , DELHI

ITA 876/CHANDI/2024[2018-19]Status: DisposedITAT Chandigarh11 Nov 2025AY 2018-19
For Appellant: Shri Suraj Bhan Nain, AdvocateFor Respondent: Shri Manav Bansal, CIT, DR

…i.e. the language of sections 56(2)(viii) and 57(iv) of the 1961 Act is plain, simple and unambiguous. There is no scope of taking outside aid for giving an interpretation to newly inserted sub-sections and clauses. Supreme Court in I.T.C. Ltd. v. CCE [2004] 7 SCC 591 held as under: "23. ........These decisions exemplify the general rule of statutory construction that words have to be construed strictly according to their ordinary and natural meaning, particularly when the statute is a fiscal one irrespective of the object with which the provision was introduced. Of course if there is ambiguity in the statutory…

KAKA SINGH ALIAS GULJAR SINGH,PATIALA vs. INCOME TAX OFFICER , PATIALA

ITA 663/CHANDI/2024[2020-21]Status: DisposedITAT Chandigarh11 Nov 2025AY 2020-21
For Respondent: \nShri Suraj Bhan Nain, Advocate

…. the language\nof sections 56(2) (viii) and 57(iv) of the 1961 Act is plain, simple and unambiguous.\nThere is no scope of taking outside aid for giving an interpretation to newly inserted\nsub-sections and clauses. Supreme Court in I.T.C. Ltd. v. CCE [2004] 7 SCC 591 held as\nunder:\n\"23. ........These decisions exemplify the general rule of statutory construction that\nwords have to be construed strictly according to their ordinary and natural meaning,\nparticularly when the statute is a fiscal one irrespective of the object with which the\nprovision was introduced. Of course if there is ambiguity in the stat…

ANJU,MOHALI vs. INCOME TAX OFFICER WARD 6 (1) , MOHALI

ITA 563/CHANDI/2024[2015-16]Status: DisposedITAT Chandigarh11 Nov 2025AY 2015-16
For Appellant: \nShri Suraj Bhan Nain, AdvocateFor Respondent: \nShri Manav Bansal, CIT, DR

…. the language\nof sections 56(2) (viii) and 57(iv) of the 1961 Act is plain, simple and unambiguous.\nThere is no scope of taking outside aid for giving an interpretation to newly inserted\nsub-sections and clauses. Supreme Court in I.T.C. Ltd. v. CCE [2004] 7 SCC 591 held as\nunder:\n\"23. ........These decisions exemplify the general rule of statutory construction that\nwords have to be construed strictly according to their ordinary and natural meaning,\nparticularly when the statute is a fiscal one irrespective of the object with which the\nprovision was introduced. Of course if there is ambiguity in the stat…

INCOME TAX OFFICER, FATEHABAD vs. MAHESH NAGPAL, FATEHABAD

ITA 531/CHANDI/2024[2018-19]Status: DisposedITAT Chandigarh11 Nov 2025AY 2018-19

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

For Appellant: Shri Suraj Bhan Nain, AdvocateFor Respondent: Shri Manav Bansal, CIT, DR

…i.e. the language of sections 56(2)(viii) and 57(iv) of the 1961 Act is plain, simple and unambiguous. There is no scope of taking outside aid for giving an interpretation to newly inserted sub-sections and clauses. Supreme Court in I.T.C. Ltd. v. CCE [2004] 7 SCC 591 held as under: "23. ........These decisions exemplify the general rule of statutory construction that words have to be construed strictly according to their ordinary and natural meaning, particularly when the statute is a fiscal one irrespective of the object with which the provision was introduced. Of course if there is ambiguity in the statutory…

RAMKARAN ,PANCHKULA vs. NFAC, DELHI

Accordingly, finding no merit in the appeals, the same are hereby\ndismissed

ITA 503/CHANDI/2024[2015-16]Status: DisposedITAT Chandigarh11 Nov 2025AY 2015-16
For Respondent: \nShri Suraj Bhan Nain, Advocate

…. the language\nof sections 56(2) (viii) and 57(iv) of the 1961 Act is plain, simple and unambiguous.\nThere is no scope of taking outside aid for giving an interpretation to newly inserted\nsub-sections and clauses. Supreme Court in I.T.C. Ltd. v. CCE [2004] 7 SCC 591 held as\nunder:\n\"23. ........These decisions exemplify the general rule of statutory construction that\nwords have to be construed strictly according to their ordinary and natural meaning,\nparticularly when the statute is a fiscal one irrespective of the object with which the\nprovision was introduced. Of course if there is ambiguity in the stat…

SARVAN SINGH,AMBALA vs. INCOME TAX OFFICER-WARD 4, AMBALA

ITA 458/CHANDI/2024[2018-19]Status: DisposedITAT Chandigarh11 Nov 2025AY 2018-19

…. the language\nof sections 56(2) (viii) and 57(iv) of the 1961 Act is plain, simple and unambiguous.\nThere is no scope of taking outside aid for giving an interpretation to newly inserted\nsub-sections and clauses. Supreme Court in I.T.C. Ltd. v. CCE [2004] 7 SCC 591 held as\nunder:\n\"23. ........These decisions exemplify the general rule of statutory construction that\nwords have to be construed strictly according to their ordinary and natural meaning,\nparticularly when the statute is a fiscal one irrespective of the object with which the\nprovision was introduced. Of course if there is ambiguity in the stat…

SAMAY SINGH,YAMUNANAGAR vs. ITO-WARD (5), YAMUNANAGAR

ITA 435/CHANDI/2024[2017-18]Status: DisposedITAT Chandigarh11 Nov 2025AY 2017-18

…. the language\nof sections 56(2) (viii) and 57(iv) of the 1961 Act is plain, simple and unambiguous.\nThere is no scope of taking outside aid for giving an interpretation to newly inserted\nsub-sections and clauses. Supreme Court in I.T.C. Ltd. v. CCE [2004] 7 SCC 591 held as\nunder:\n\"23. ........These decisions exemplify the general rule of statutory construction that\nwords have to be construed strictly according to their ordinary and natural meaning,\nparticularly when the statute is a fiscal one irrespective of the object with which the\nprovision was introduced. Of course if there is ambiguity in the stat…

INCOME TAX OFFICER, INCOME TAX OFFICE BARNALA vs. LAKHVIR SINGH, GRAIN MARKET, BARNALA

ITA 245/CHANDI/2024[2021-22]Status: DisposedITAT Chandigarh11 Nov 2025AY 2021-22
For Appellant: \nShri Suraj Bhan Nain, AdvocateFor Respondent: \nShri Manav Bansal, CIT, DR

…. the language\nof sections 56(2) (viii) and 57(iv) of the 1961 Act is plain, simple and unambiguous.\nThere is no scope of taking outside aid for giving an interpretation to newly inserted\nsub-sections and clauses. Supreme Court in I.T.C. Ltd. v. CCE [2004] 7 SCC 591 held as\nunder:\n\"23. ........These decisions exemplify the general rule of statutory construction that\nwords have to be construed strictly according to their ordinary and natural meaning,\nparticularly when the statute is a fiscal one irrespective of the object with which the\nprovision was introduced. Of course if there is ambiguity in the stat…

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