In Brief
VVF (India) Limited, a chemical manufacturer, was assessed for value-added tax under Maharashtra law. It had previously paid disputed amounts under protest. When new rules mandating a pre-deposit to file appeals were introduced, the authority rejected its appeal, arguing protest payments could not count toward the required deposit. The Supreme Court held that taxing statutes must be construed strictly according to plain language. Since the statute requires 10 per cent of the tax disputed, and the protest payment represents tax paid, it must be counted toward the deposit. The Court allowed the appeal and restored the matter to the appellate authority for verification.
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