I.T.C. Ltd. v. CCE

7 SCC 591Supreme Court of India2004#2095 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 366,314 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

Sh. Gurinder Singh Grewal L/H of Parneet Kaur Grewal, Chandigarh vs. ACIT, Circle 4(1), Chandigarh

ITA 129/CHANDI/2023[2017-18]Status: DisposedITAT Chandigarh11 Nov 2025AY 2017-18
For Respondent: Shri Suraj Bhan Nain, Advocate

…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…

M/S Yograj Chaudhary, Yamuna Nagar vs. ITO, Ward-5, Yamuna Nagar

ITA 116/CHANDI/2023[2017-18]Status: DisposedITAT Chandigarh11 Nov 2025AY 2017-18

…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…

Sh. Ramesh Chand, Jagadhri vs. ITO, Ward-3, Yamuna Nagar

ITA 731/CHANDI/2022[2015-16]Status: DisposedITAT Chandigarh11 Nov 2025AY 2015-16
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…

Sh. Suresh Pal, Yamuna Nagar vs. ITO, Ward 5, Yamuna Nagar

ITA 668/CHANDI/2022[2018-19]Status: DisposedITAT Chandigarh11 Nov 2025AY 2018-19

…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…

Sh. Kulbir Singh S/O Sh. Jagir Singh, Pinjore vs. ITO, Ward 2, Panchkula

ITA 641/CHANDI/2022[2015-16]Status: DisposedITAT Chandigarh11 Nov 2025AY 2015-16

…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…

Saroj Chaudhary Bala, Panchkula vs. ITO, Ward-4, Panchkula

ITA 635/CHANDI/2022[2017-18]Status: DisposedITAT Chandigarh11 Nov 2025AY 2017-18

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…

Smt. Shankri Devi, Panchkula vs. ACIT, Panckula Circle, Panchkula

ITA 596/CHANDI/2022[2013-14]Status: DisposedITAT Chandigarh11 Nov 2025AY 2013-14

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…

Harmala, Chandigarh vs. ITO, Ward 1(1), Nangal

ITA 432/CHANDI/2022[2015-16]Status: DisposedITAT Chandigarh11 Nov 2025AY 2015-16

…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…

Amrinder Singh Khubber, Ambala vs. ITO, W-5, Ambala

ITA 1044/CHANDI/2019[2013-14]Status: DisposedITAT Chandigarh11 Nov 2025AY 2013-14

…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…

Amrinder Singh Khubber, Ambala vs. ITO, W-5, Ambala

ITA 1043/CHANDI/2019[2012-13]Status: DisposedITAT Chandigarh11 Nov 2025AY 2012-13

…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…

Vijay Singh Chauhan, Noida vs. ITO, Ward-2(5), Noida

The appeal of the assessee is hereby dismissed

ITA 2561/DEL/2023[2015-16]Status: DisposedITAT Delhi26 Sept 2025AY 2015-16

Bench: Shri Sudhir Pareek & Shri Avdhesh Kumar Mishravijay Singh Chauhan, Income Tax Officer, House No.-193, Gali No.-3, Vs. Ward- 2(5), Noida, Village Chhalera, Sector-44, Uttar Pradesh, Noida, Uttar Pradesh India. India. Pan No: Aeipc4637E Appellant Respondent Assessee By : Sh. Naveen Kumar, Adv. Revenue By : Ms. Harpreet Kaur Hansra, Sr. Dr Date Of Hearing: 01.07.2025 Date Of Pronouncement: 26.09.2025 Order Per Sudhir Pareek, Jm: The Aforetitled Appeal Has Been Preferred Against The Order Of National Faceless Appeal Centre, Delhi [Hereinafter, In Short, ‘Cit(A)’] Dated 17.07.2023 For Ay 2015-16, By Which Appeal Of The Assessee Was Dismissed.

For Appellant: Sh. Naveen Kumar, AdvFor Respondent: Ms. Harpreet Kaur Hansra, Sr. DR
Section 10(37)Section 143(2)Section 28Section 34

…ght out by the appellant. The language of the above section is plain, simple and unambiguous. There is no scope of taking outside aide for giving interpretation to the newly inserted sub-sections and clauses. The Hon'ble Supreme Court in ITC Ltd. vs CCE(2004) 7 SCC 591 held as under: "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 language, re…

Veena Shah, Panipat vs. Pr CIT, Rohtak

The appeal stands dismissed

ITA 1222/DEL/2023[2018-19]Status: DisposedITAT Delhi28 Jun 2024AY 2018-19

Bench: SHRI VIKAS AWASTHY (Judicial Member), SHRI AVDHESH KUMAR MISHRA (Accountant Member)

Section 10(37)Section 143Section 143(3)Section 263Section 28Section 56(2)(viii)

…e language of section 56(2)(viii) and 57(iv) of the 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. The Hon'ble Supreme Court in the case of ITC Ltd. [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 langu…

Shri Jayantilal Paghadal, at Charan Samdhiyala, New Area Plot, Taluka Jetpur, District Rajkot-365480 vs. The Income Tax Officer, Ward - 1 (2) (3), Rajkot

In the result, the appeal of the assessee is dismissed

ITA 252/RJT/2022[2016-17]Status: DisposedITAT Rajkot13 Dec 2023AY 2016-17

Bench: Ms. Suchitra Kamble (Judicial Member), Shri Waseem Ahmed (Accountant Member)

For Appellant: NoneFor Respondent: Shri Ashish Kumar Pandey, Sr. D.R
Section 10(37)Section 143(2)Section 145ASection 193Section 28Section 56Section 56(2)(viii)

…, 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 subsections 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 5 I.T.A No. 252/Rjt/2022 A.Y.…

Smt. Renu Jain, New Delhi vs. ITO, Ward 5(2), Jaipur

In the result, the matter is decided in favour of the assessee and against the Revenue and the sole ground of appeal is allowed

ITA 96/JPR/2020[2011-12]Status: DisposedITAT Jaipur06 Mar 2020AY 2011-12
For Appellant: Shri Akshay Shah (C.A.)For Respondent: Miss Chanchal Meena (JCIT)
Section 139Section 143(3)Section 147Section 148Section 54F

…hed before the expiry of one year from the end of the relevant assessment year or before the completion of the assessment whichever is earlier under Sub-section (4) of Section 139 of the Income Tax Act, 1961. 17 Renu Jain vs. ITO 7. I.T.C. Ltd. v. CCE [2004] 7 SCC 591 (SC), it has been held as under :— 23. Presumably the phrase "badly drafted" was used to mean that the language of the Entry was ambiguous. In case of such ambiguity 'close reasoning' will be employed - but without stretching the language to arrive at the only reasonable construction. These decisions exemplify the general rule of statutory construc…

G.T.C. Industries Ltd ( Formerly Golden Tobacco Co Ltd), Mumbai vs. Asst CIT Cen Cir 9

In the result assessee‟s appeal is allowed

ITA 5996/MUM/1993[1884-85]Status: DisposedITAT Mumbai07 Mar 2017AY 1884-85

Bench: Shri R.C.Sharma, Am, Shri Saktijit Dey Jm & Shri Amit Shukla, Jm

Section 143(3)Section 256(1)

…n. 4. On the facts, therefore, the Tribunal found that the case of the Department had not in fact been made out. Apart from this, the Tribunal also relied upon the judgment of this Court in ITC Ltd., vs. Commissioner of Central Excise, New Delhi & Anr. (2004) 7 SCC 591) = 2004- TIOL-75-SC-CX and found that on a reading of the said judgment, the alternative submission of the respondent was also made out. We do not find any error in the said judgment either on fact or on law. 5. In the aforesaid circumstances, the appeal lacks merit and is, accordingly, dismissed. 49. The aforesaid judgment of Hon‟ble Supreme Cour…