J. SRINIVASA RAO vs GOVT. OF A.P.

The Supreme Court upheld the validity of the notification dated 27.04.1997 under the Andhra Pradesh Motor Vehicles Taxation Act, 1963, which modified the tax rate for Maxi Cabs based on seating capacity. The Court emphasized that in cases of ambiguity in taxing statutes, the interpretation should favor the taxpayer, as established in prior rulings. The Court found that the High Court's dismissal of the writ petition was justified, affirming that the provisions of the Act were harmoniously construed and the tax was compensatory in nature.