contemporanea expositio - "administrative construction (that is, contemporaneous construction placed by administrative or executive officers charged with executing a statute) generally should be clearly wrong before it is overturned; such a construction, commonly referred to as practical construction, although non-controlling, is nevertheless entitled to considerable weight, it is highly persuasive" (Crawford on Statutory Construction, 1940 edition). |
In K. P. Varghese vs ITO (131 ITR 597 SC), it was pointed out by the apex court that not only are the circulars and instructions issued by the CBDT in exercise of the power under Section 119 binding on the authorities administering the Tax Department, but they are also clearly in the nature of contemporanea expositio, furnishing legitimate aid to the construction of the Act.