Tarlok Singh Chauhan, J. The instant case is rather an unusual one where the Himachal Pradesh Tax Tribunal (for short ‘Tribunal’) though had quashed all the proceedings against the petitioner but then proceeded to burden it with Rs. 20 lakhs, as costs, that too, only on the ground that “it should not be allowed to get the benefit of technicalities of law and the wrongs committed by the Assessing Authority”. 2. However, before we proceed to determine the question on merit, it would be necessary to recapitulate few facts, which are as under: 3. The petitioner is a registered dealer under the Himachal Pradesh Value Added Tax Act, 2005 (for short ‘VAT Act, 2005’) and also under the Central Sales Tax Act, 1956) for manufacturing and trading of drugs and medicines in the State of Himachal Pradesh. The petitioner in the year 2005 has set up a factory for manufacturing of drugs at Baddi. 4. The assessment for the year 2005-06 framed by the Assessing Authority was reopened under the VAT Act, 2005 and the petitioner was issued notice in Form Vat-XXXIX. 5. These proceedings culminated in the imposition of penalty upon the petitioner to the tune of Rs. 84,44,838/-. Though an appeal against the same was filed before the Appellate Authority, however, the same was dismissed vide order dated 7.5.2009. 6. The petitioner thereafter filed second appeal before the Tribunal, which was registered as Appeal No. 70/2009 and came up for consideration on 18.9.2010, and as already observed earlier, the Tribunal though set aside the order passed by the Assessing Authority as also the Appellate Authority, however, at the same time proceeded to impose costs of Rs. 20 lakhs on the petitioner only for the reason that it could not be permitted to take the benefit of technicalities of law and the wrongs committed by the Assessing Authority. 7. This would be clearly evident from the operative portion of the order, which reads thus: “Therefore, keeping in view the above circumstances it is not necessary to discuss each and every item and attending circumstances of all the items. 7. This would be clearly evident from the operative portion of the order, which reads thus: “Therefore, keeping in view the above circumstances it is not necessary to discuss each and every item and attending circumstances of all the items. This court comes to the conclusion that the penalty imposed is in violation of statutory provisions and liable to be quashed and is hereby quashed alongwith order of Appellate Authority but the dealer should not be allowed to get the benefit of technicalities of law and wrongs committed by the Assessing Authority and, therefore, I feel it necessary in the interest of justice and as well as in the interest of revenue also that the dealer must be burdened with heavy cost while allowing its appeal and costs are quantified as Rs. 20,00,000/- (Rupees twenty lakhs) which I feel is necessary and expedient and the appeal is accordingly disposed of and records of the lower authorities be sent back.” 8. We have heard the learned counsel for the parties and have gone through the material placed on record. 9. We are appalled to see the manner in which the appeal has been disposed of. 10. It is more than settled that the statutory Tribunals must function within their bound and their decisions should not be arbitrary, fanciful or based on irrelevant consideration. 11. It is equally settled that fiscal statutes must be strictly interpreted and in determining liability of a subject to tax one must have regard to the strict letter of law and not merely spirit of the statute or the subsistence of the law. If the Revenue satisfies the Court that the case falls strictly within the provision of the law, the subject can be taxed. On the other hand, if the case is not covered within the four corners of the provisions of the taxing statutes, no tax can be imposed by inference or by analogy or by trying to probe into the intentions of the legislature and by considering what was the substance of the matter. 12. Apart from the above, there is no equity on either side in tax matters and nothing can be read which is not provided for in the statute. 13. 12. Apart from the above, there is no equity on either side in tax matters and nothing can be read which is not provided for in the statute. 13. The fundamental principle that serves as guidance to understand the fiscal legislations and the duty of the Court while dwelling upon the interpretation of the taxing statute has been construed by the Hon’ble Supreme Court in State of Rajasthan and others vs. Basant Agrotech (India) Limited, (2013) 15 SCC 1 , and it shall be apt to reproduce the relevant paras as under: “[12] Before we appreciate the controversy that has travelled to this Court, we think it necessary to state the fundamental principles that serve as guidance to understand the fiscal legislations and the duty of the Court while dwelling upon the interpretation of taxing statutes. [13] In A.V. Fernandez v. The State of Kerala, 1957 AIR (SC) 657, Bhagwati, J. referred to a passage from Partington v. The Attorney General, 1869 4 HL 100 at p. 122(B) which is as follows: - "As I understand the principle of all fiscal legislation it is this : if the person sought to be taxed, comes within the letter of the law he must be taxed however great the hardship may appear to the judicial mind to be. On the other hand, if the Crown, seeking to recover the tax, cannot bring the subject within the letter of the law, the subject is free, however apparently within the spirit of the law the case might otherwise appear to be." [14] The said passage, as has been stated in the said pronouncement, was quoted with approval by the Privy Council in Bank of Chettinad v. Income-tax Commr., 1940 AIR(PC) 183 and the Privy Council had registered its protest against the suggestion that in revenue cases "the substance of the matter" may be regarded as distinguished from the strict legal position. Proceeding further the learned Judge stated that: "It is no doubt true that in construing fiscal statutes and in determining the liability of a subject to tax one must have regard to the strict letter of the law and not merely to the spirit of the statute or the substance of the law. If the Revenue satisfies the Court that the case falls strictly within the provision of the law, the subject can be taxed. If the Revenue satisfies the Court that the case falls strictly within the provision of the law, the subject can be taxed. If, on the other hand, the case is not covered within the four corners of the provisions of the taxing statute, no tax can be imposed by inference or by analogy or by trying to probe into the intentions of the legislature and by considering what was the substance of the matter." [15] In Commissioner of Salex-tax, U.P. v. Modi Sugar Mills Ltd., 1961 AIR(SC) 1047, Shah, J., speaking for the majority in the Constitution Bench, has observed thus: - "In interpreting a taxing statute, equitable considerations are entirely out of place. Nor can taxing statutes be interpreted on any presumptions or assumptions. The Court must look squarely at the words of the statute and interpret them. It must interpret a taxing statute in the light of what is clearly expressed : if cannot imply anything which is not expressed; it cannot import provisions in the statutes so as to supply any assumed deficiency." [16] In Commissioner of Income-tax, Madras v. Kasturi and Sons Ltd., 1999 AIR(SC) 1275, a two-Judge Bench has approvingly quoted a passage from the book "Principles of Statutory Interpretation" by Justice G.P. Singh, Sixth Edition 1966, which is as follows: - "The well established rule in the familiar words of LORD WENSLEYDALE, reaffirmed by LORD HALSBURY and LORD SIMONDS, means : "The subject is not to be taxed without clear words for that purpose; and also that every Act of Parliament must be read according to the natural construction of its words". In a classic passage LORD CAIRNS stated that the principle thus: "If the person sought to be taxed comes within the letter of the law he must be taxed, however great the hardship may appear to the judicial mind to be. On the other hand, if the Crown seeking to recover the tax, cannot bring the subject within the letter of the law, the subject is free, however apparently within the spirit of law the case might otherwise appear to be. On the other hand, if the Crown seeking to recover the tax, cannot bring the subject within the letter of the law, the subject is free, however apparently within the spirit of law the case might otherwise appear to be. In other words, if there be admissible in any statute, what is called an equitable, construction, certainly, such a construction is not admissible in a taxing statute where you can simply adhere to the words of the statute." VISCOUNT SIMON quoted with approval a passage from Rowlatt, J. expressing the principle in the following words: "In a taxing Act one has to look merely at what is clearly said. There is no room for any intendment. There is no equity about a tax. There is no presumption as to tax. Nothing is to be read in, nothing is to be implied. One can only look fairly at the language used." Relying upon this passage Lord Upjohn said : "Fiscal measures are not built upon any theory of taxation". This passage presently finds place at page 826, Twelfth Edition 2012 of "Principle of Statutory Interpretation" by G.P. Singh." 14. Adverting to the facts, what we find more intriguing is that once the Tribunal had come to the conclusion that the orders passed by both the authorities below, i.e. Assessing Authority and Appellate Authority, were not sustainable in the eyes of law and there was merit in the appeal filed by the petitioner, then how it still proceeded to not only impose costs but exorbitant costs. 15. As regards costs, the accepted principle is that the costs shall follow the event. Unless the successful party is guilty of misconduct or there is any other good cause or reason for depriving the party of it. 16. However, imposing costs upon the successful party, that too, only on the ground of it being legally entitled to benefit of a statute is totally unheard of. After all, the object of awarding costs is to indemnify a party against the expenses of the successful party incurred during the process of vindicating its rights before the Court. 17. 16. However, imposing costs upon the successful party, that too, only on the ground of it being legally entitled to benefit of a statute is totally unheard of. After all, the object of awarding costs is to indemnify a party against the expenses of the successful party incurred during the process of vindicating its rights before the Court. 17. In Vinod Seth vs. Devinder Bajaj, (2010) 8 SCC 1 , the Hon’ble Supreme Court laid down the following goals, which were intended to be achieved by imposing costs: (a) expenditure incurred for the giving of any notice required to be given by law before the institution of the suit; (b) expenditure incurred on any notice which, though not required to be given by law, has been given by any party to the suit to any other party before the institution of the suit; (c) expenditure incurred on the typing, writing or printing of pleadings filed by any party; (d) charges paid by a party for inspection of the records of the court for the purposes of the suit; (e) expenditure incurred by a party for producing witnesses, even though not summoned through courts; and (f) in the case of appeals, charges incurred by a party for obtaining any copies of judgments and decrees which are required to be filed along with the memorandum of appeal." 18. It is a trite if a person had not been brought within the ambit of charging section of a taxing statute by clear words; he could not be taxed at all, directly or indirectly. What the learned Tribunal in fact has done is virtually nullify the provisions of the statute by indirectly taxing the petitioner by imposing exorbitant costs of Rs. 20 lakhs. 19. It needs no emphasis that no person can be persecuted only for having resorted to a legal remedy, that too, which has ultimately concluded in his favour. 20. In view of the reasons stated hereinabove, we find merit in this petition and the same is allowed and order passed by the Tribunal on 18.9.2010 is quashed and set aside. 21. It needs no emphasis that no person can be persecuted only for having resorted to a legal remedy, that too, which has ultimately concluded in his favour. 20. In view of the reasons stated hereinabove, we find merit in this petition and the same is allowed and order passed by the Tribunal on 18.9.2010 is quashed and set aside. 21. Normally, in such like cases, matter would be required to be remitted back to the Authority whose order has been set aside, however, in this case, there is no necessity of doing so for the simple reason that the State has not chosen to assail the order passed by the Tribunal whereby the orders passed by the Assessing Authority and thereafter Appellate Authority have been ordered to be set aside. It is only the petitioner, who is aggrieved by the impugned order and has approached this Court by filing the instant petition, whereas, the respondent has remained contended with the order passed by the Tribunal, and the same insofar as the State is concerned, has attained finality. 22. The petition is allowed in the aforesaid terms leaving the parties to bear their own costs.