Commnr. Of Customs (Import), Mumbai vs M/S. Dilip Kumar And Company

The Supreme Court, in this Constitution Bench, reconsidered the interpretative rule established in Sun Export Corporation v. Collector of Customs, Bombay, regarding tax exemption provisions. The Court held that ambiguities in tax exemption notifications should not automatically favor the assessee, as previously ruled, but must be interpreted strictly in accordance with the specific language of the notification. The judgment clarifies that the applicability of exemptions must be determined based on the precise terms of the notification, thereby overruling the earlier interpretation in the Sun Export Case.