In Brief
Nagar Nigam, Allahabad sought to levy licence fees on the Life Insurance Corporation of India as an "insurance company" under a municipal notification. The Supreme Court dismissed the appeal, agreeing with the High Court that LIC is not covered by the notification. The Court found a clear statutory distinction between general insurance companies (regulated under the Insurance Act, 1958) and life insurance corporations (regulated under the Life Insurance Corporation of India Act, 1956). Section 438 of the Uttar Pradesh Municipal Corporations Act, 1959 addresses licence fees only for activities involving keeping or manufacturing goods on premises, not service-based businesses like insurance. The Court applied the principle that ambiguous tax/fee provisions should be interpreted in favour of the person to be burdened.
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