The Supreme Court held amalgamated companies cannot claim set off of predecessor losses under Kerala Agricultural Income Tax Act without explicit provision. Dismissing Aspinwall appeals, it ruled such benefits require statutory backing and proper notice during amalgamation proceedings.
The Supreme Court reiterated that taxation statutes must be interpreted strictly and courts must follow their plain meaning when language is clear and unambiguous. Justices J. B. Pardiwala and K. V. Vishwanathan warned against adding words to laws under assumed legislative intent.
