The appellants no doubt contrast Entry 86 with Entry 82 and contend that the said contrast brings out an element of limitation · <>r restr'ction which should be imported in construing Entry 86. Entry 82 refers to taxes on income other than agricultural income. The argument is that the power to levy taxes on income is not conditioned by reference to individuals or companies; it is an unlimited extensive · power. In contrast with this Entry, it is urged that limitation is introduced by Entry 86, because it seeks to confer power to levy taxes on the capital value of the assets of individuals and companies. The assessees are indicated by this Entry, and that that itself introduces an element of limitation. The appellants attempt to place their case alternatively by emphasising C the fact that the word "individuals" in the context cannot mean companies, because companies are separately and distinctly mentioned; that again, it is said, introduces an element of limitation <>n the denotation of the word "individuals". "Individuals", therefore, must mean individuals and cannot mean groups of individuals, that is the main contention raised by the appellants. We are not impressed by this argument. It is true that Entry 82 does not refer to the assessees, and that is natural because what it purports to do is to recognise the legislative competence of Parliament to levy taxes on income, the only limitation being that the income must be other than agricultural income. Since Entry 86 refers to taxes on the capital value of the assets, the Constitn· E lion-makers must have thought that it was necessary to specify whose assets should be subject to the taxes contemplated by the Entry, and that explains why individuals and' companies are mentioned. Since compani!lS are specifically mentioned along with individuals, it may be permissible to contend that companies in the context are not included in the word "individuals", or it may perhaps be that since Entry 86 wanted to specify that the taxes leviable under it have to be taxes on the capital of the comoanies, it was thought desirable· that companies should be specified as a matter of precaution along with individuals. How· ever that may be, it is not easy to understand why the word "inrlividuals" cannot take in its sweep groups of individuals like G Hindu undivided families. The use of the word "individuals" in the nlural is not of any soecial significance, because under s. 13(2) of the General Clauses Act, 1897 (No. 10 of 1897), words in the singular shall include the plural, and vice versa.
