Section 80-IE of the Income Tax Act

A fiscal statute must be interpreted strictly based on its plain language, without substituting judicial impressions for legislative intent. Exemptions and exclusions within such statutes must also be construed strictly and cannot be extended through interpretation.

Expenditure incurred by pharmaceutical companies on freebies provided to medical practitioners is not deductible under Explanation 1 to Section 37(1) of the Income-tax Act, as such gifting is prohibited by the Medical Council Regulations, 2002. The court also held that what is directly prohibited by law cannot be indirectly evaded through contrivance.

When interpreting fiscal legislation, courts must adhere strictly to the plain and unambiguous language of the statute, without introducing intendment, equity, or words not present in the text, irrespective of perceived hardship. The legislative intent must be gathered solely from what has been said and not said in the statutory language.

The computation provisions for long-term capital gains, including the benefit of indexation under sections 45, 48, and 112, are applicable when determining book profits under section 115JB(5) for Minimum Alternate Tax, unless explicitly overridden, ensuring the 'real income' is taxed.

A trust substantially satisfying the conditions for exemption under Section 11 cannot be denied that exemption solely due to a procedural delay in furnishing the audit report in Form No. 10, as the submission of the form is considered a procedural rather than a mandatory condition.