In a taxing Act, one has to look at what is clearly said. There is no room for intendment as to a tax

Majanja referred to the dictum of Lord Simonds in Russell v Scott [1948] 2 ALL ER 5 where he stated:-“My Lords, there is a maxim of income tax law which, though it may sometimes be overstressed yet ought not to be forgotten. It is that the subject is not to be taxed unless the words of the taxing statute unambiguously impose the tax upon him.”