When construing a provision of a taxing statute such as the Income-tax Act, 2025, what is the settled…

In K.P. Varghese v. Income Tax Officer (1981), the Supreme Court explained that while a marginal note (or section heading) to a statutory provision in an income-tax enactment (now the Income-tax Act, 2025; formerly the Income-tax Act, 1961) 'cannot be referred to for construing the section, it can certainly be relied upon as indicating the drift of the section or, to use the words of Collins M.R., to show what the section is dealing with'. It cannot control clear enacting words in the body of the section, nor must it be ignored completely.