Apart from statute, there is no liability to pay any tax and no antecedent relationship between the taxpayer and the taxing authority so that no reasoning founded on any such assumed liability or relationship can be used in the construction of the Act1. This is the reason why taxing Acts are construed with strictness and no payment can be exacted from the subject which is not clearly and unequivocally required by Act of Parliament. However, what is clear and unequivocal is often a matter of debate and it has been said that the task of the court is to find a fair and reasonable construction without leaning to one side or the other2.
This principle of strict interpretation was well stated by Lord Cairns in Partington v A-G3:
'If
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