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Navinchandra Mafatlal v. The Commissioner of Income Tax, Bombay City - (Supreme Court) (01 Nov 1954)

Giving a constitutional enactment the widest possible meaning

MANU/SC/0070/1954

Direct Taxation

It seems prerequisite that any case seeking to send aftershocks into the legal system should have the word Mafatlal in it. Certainly, Mr. Mafatlal here may not quite comprise the elite constitutional club of his eponymous brethren, but its amplitude is no less wide. Considering if capital gain could be construed as income, the Court concluded that income in “its natural meaning embraces any profit or gain which is actually received”. In its obiter the Court provided much interpretational fodder and freedom to courts in the future; it noted, “words [in a constitutional enactment] should be read in their ordinary, natural and grammatical meaning… the most liberal construction should be upon the words”.

Relevant : Wallace Brothers and Co. Ltd. vs. The Commissioner of Income Tax MANU/PR/0011/1948 United Provinces vs. Mt. Atiqa Begum and Ors. MANU/FE/0003/1940 The State of Bombay and Anr. vs. F.N. Balsara MANU/SC/0009/1951

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