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Supreme Court of India 2022-01-07 allowed

State of Maharashtra vs Shri Vile Parle Kelvani Mandal & Ors

Bench: 2 — M.R. Shah

In Brief

Charitable education institutions registered under Maharashtra's Public Trusts Act challenged electricity duty levied after September 2016. The Supreme Court held that these institutions are not exempt from electricity duty under the Maharashtra Electricity Duty Act, 2016. Although the prior 1958 Act specifically exempted charitable schools and colleges, the 2016 Act omitted this exemption. The Court applied strict literal interpretation to the exemption provision, holding that when statutory language is plain and unambiguous, courts must not resort to purposive construction, doctrines of omission, or other interpretative tools to read in missing exemptions. The High Court's order setting aside the duty was reversed and the appeal allowed.

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Tax Law Statutory Interpretation Exemption Provisions Electricity Duty Charitable Institutions Education

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