Why Department should prefer Sec. 16(2) over Sec. 16(4)? "Even if two interpretations were possible, the well known canon of construction is that the construction beneficial to the citizen should be adopted." ~ Bombay High Court in Empire Dyeing and Manufacturing Co. Ltd.

(1977) 40 STC 1 : (1977) 6 CTR Bom 706 : 1978 TAX. L.R. 2058 : (1977) 1 ELT (J34) (Bom.) What is your view?