Philadelphia v. Depuy

Opinion by

Mr. Justice Roberts,

This litigation centers around one paragraph of the Act of June 1, 1889, P. L. 420, §23, as amended, 72 P.S. §2181 (Supp. 1967). The act generally imposes an annual tax of 14 mills on the gross receipts of certain enumerated utilities; the section directly involved in this litigation exempts from taxation the gross receipts of municipally owned or operated public utilities to the extent that these gross receipts are derived from business done inside the limits of the municipality. Municipal gas companies, however, are denied this exemption by the language of the…