Where the construction of any taxing entry is changed,the burden of proof to justify the change lies on the department.
Although equity and taxation are quite strangers, but a construction which results in equity rather than in injustice, should be preferred to the literal construction.
Where the literal interpretation leads to absurd or unintended results, the language of the statute can be modified to accord with the legislative intention and to avoid absurdity also applies in interpreting a taxing statute.