In interpreting taxing statutes, the courts follow established principles to ensure consistency and adherence to the statute’s language. Below are three key rules of literal interpretation in taxation:

1. Literal Rule:
   • When the language of the statute is clear and unambiguous, the courts must give the words their ordinary meaning. Even if the result may seem unjust, the courts have no authority to apply a different interpretation. The statute must be applied as written. For instance, if the wording explicitly imposes a tax, the courts will enforce it without adding any additional interpretation or modifying its meaning.
2. No Tax Without Clear Words:
   • This principle emphasizes that no individual or entity can be taxed unless the law clearly imposes the tax. If the statute does not explicitly include the person or transaction within its scope, the courts will not extend its interpretation to impose a tax. This ensures that tax obligations are only imposed based on explicit provisions in the tax legislation.
3. Plain Meaning Prohibition on Judicial Construction:
   • If the language of the Act is straightforward and unequivocal, the court is not allowed to reinterpret or construct an alternative meaning. There is no presumption in tax law, and nothing should be inferred or implied that is not expressly stated in the language of the statute. If the taxpayer does not fall within the explicit parameters of the statute, no tax can be imposed.

These principles form the foundation of literal interpretation in tax law, ensuring that tax laws are applied strictly as written, without judicial expansion or modification.