Any Ambiguity in Tax Laws is Construed in Favor of the Taxpayer

“even though taxation is acceptable and even essential in democratic societies, taxation laws that have the effect of depriving citizens of their property by imposing pecuniary burdens resulting also in penal consequences must be interpreted with great caution. In this respect, it is paramount that their provisions must be express and clear so as to leave no room for ambiguity", The Court further noted that "any ambiguity in such a law must be resolved in favour of the taxpayer and not the Public Revenue Authorities, which are responsible for their implementation"