A company incorporated to deal in real property commercially took a market place on lease and let out shops and stalls. The Supreme Court held the income was business income taxable under section 10, not under the residuary section 12, since the letting was part of its trading activity.
This page shows the compact analysis of this judgement. The full analysis — procedural history, issue-by-issue holdings with ratio and obiter, advocates, and paragraph-level evidence for every claim — is being added to the record in batches and will appear here when this judgement has been through it.
·980
; i
A S. G. MERCANTILE CORPN. (P) L1D.
v.
| TilEC.I.T., CALCUTI' A _January_4,1972 |
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| .[J.M.SHELAT,I.D.DuA,H.R.KHANNAANDG:K.MITTER,JJ.] _Income TaxAct;1922,ss.10,1~ompany_formed with the object ofacquiring or taking on lease laltds buildingset'C.c:nddealing withthem .commercially-Companytaking on lease market place andlettingitout- _Incomefromtheleasehold property whethertobeassessed unde s._10 ors. 12-..:.Tests forpetermtning. · |
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| Theappellant company was formed withtheobject,_interalia,_topur- .c:hase,takeon leaseorotherwise acquireandtohold, cultivate, improve, lease, sell, exchange, mortgage,orotherwise dispo_eoflandsorhouses **.**andotherreal and personal propertyandtodeal with the same commer- cially.Thecompanytookonleaseamarket placeona monthlyrentwith therighttosub-let the different pOrtions.Thecompany'saCtivity,dl¢ng theperiod coveredbythe assessment years 1956-'56, 1957-'5& '3Ild 195p-'59 wasthatofdevelopingthedemised premisesandlettingouttheportions ofthesame asshops,stallsandground space.Inassessment proceedings, thecompany claimed that its incomefromthelease hold propertyfqrthe .assessment yearshadtobeassessed unders.10oftheIncomeT!!XAct. 1922 as Jeitingomofproperlywasits business authorised by the,¢emo- randumofassociation.Theb_lcoroeTaxOfficer,andtheAppellateA,8sis- tantCommi sioner in appel, rejectedthe company's claim and· made assessment unders.12oftheActas "income· from other.source."The .appellate Tribunal held thattheincomeoftheappellant companyfrom sub-lettingofthe stalls was income from business· taxable unders.10of theAct. AccordingtotheTribunalthedecision could onlytum1,1pon theobject for whichthecompany was formed and upon the activities·.of thecompany during the relevant accounting years. TheHigh COurt, ·n reference, answeredthatthe income wasnotassessaoleunders.:10. ·It observedthatby lettingoutshops and stalls·theassessee could notbosaid tobecarrying on any activity inthenatureoftradeorwas dealing with . themcommercially. Inappeal bypecialleave, |
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| HELD:Theincome was assesSable unders.10andnotunders.12 ·OftheAct. |
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| (i)Thereisnofinding in theprentcasethatthe appellant company isthe ownerofthe property in questionoranypart thereof. Therefore, s. 9does not apply.Theliability unders.9ofthe Act isofthe owner ofthe buildingsorlands appurtenant thereto.Incase the assesseeisthe ownerhe-wouldbeliabletopaytaxunders.9 evenifthe objectofthe assesseeinpurchasingthelanded property wastopromote and develop marketthereon.Itwould also makenodifferenceifthe assessee was acompany which hadenincorpdratedwiththe objectofbuyi1.1.&and developing landed properties and promotingandsettingupmarket there- on. The incomederivedby suchacompany from_thetenants .ofthe shopsandstalls constructed on thelandforthepurposesofsettmg .up market wouldnotbetaxed as "business income" unders.10ofthe Act. .[985 D-G] |
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| _East India Housing_Esta~case, [1961]42J.T.R. 49, referred to. |
S. G. MERCANTILE CORP. v. C.I.T. (KJumna, /.)
| A | (ii)Section12which deals with the residuary headofincomecan beresortedtoonly if noneofthespecificheadsisapplicabletotheincome inquestion.Therefore, s. 12canbeinvoked in thepresentcase onlyif theapplicaoilityofs.10isexcludedbyholding that the incomeofthe appellantcompany from thep!'OJX'rtyinquestionisnotincomefrom J>usiness.[987 D) |
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| B | (iii)The dcfinitio:1oftheword"business'' ins.2(4)embracedwith- initself dealing in real property_as_also the activityoftaking a property onlease, settingup·amarket thereon andlettingoutthe shops and stalls inthemarket.Theimportant questionwhicharises inelatter case is whether the acquisitionofthepropertyonleas<!andlettinl! outofthe shopsandsfallswa;in th') course of investm:!nt orwhetherit was·sen· tiallyapartofthe business and trading operationoftheassssce.The paramountconsiri•~rationwhichwouldweighiswhetherthe acquisition |
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ofthepropertywasbywayofinvestment and whether the property wasletoutb->..causeofthe a sessee having a title in the same,orwhether theacquisition'lndlettingoutofthe propertyconstitutedbusinessand trading activityofthe asses9!e.Thequestion astowhetherthe activity isbeing carriedonbyanindividualorilcompany andinthe latter case thefurther question as to whethercarryingonofthesaid activity was theobjectofthe incorporationoftlw companyasgivenintmMemo- randumofAssociation would also have some relevance;&987E-H] |
| D | Theconclusionofthe Tribunal that the activitiesofthe appellant in taking lease and sub-letting demised premises were undertakenwith the objectofdoing business waswarrantedonthefactsofthecase. Lik:ewil>·theconclusionoftheTribunaltlntthea!)t)ellantcdmpanyin lettingoutthe lease-hold prooerty was notactina~owner butastrader wasborne out bv the materialonrecord. [990Bl |
| E | _CommissionerofInlandRevenul!!·_v._KoreanSyndicc.'teLtd.,_U92t] 12TaxCas.181and_KaranDuraDevelo,ment Co. Ltd._v.Comml.rrioner ofIncome-tax, West Bengal[1962)44I.T.R.362,referredto. Fry_v.Salisbury/{014eEstateLtd..[1930) A.C.432an,d_EastIndia Housin~_Estate_cas:,[1961)42I.T.R.49,distinguished. |
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{iv) Therefore. where,asinthe!)resent case the income canap'ro- priatelyfall under s. 10 asbeinbusineliSincome.noresortanbemade tos.12ofthe Act. CIVIL APPELLATE JURISDICTION:CivilA!)peals Nos.1748· 1750 of 1968. An?ealsbysoecial leave from the judgment and orrlerdated July 20. 1967ofthe Calcutta High Court in Income-tax Reference No. 144of1963. _M.C.Chagla_and_D. N. Mukherjee,_for theappe~lant(inall the a?peals). |
| _S.C. Monchrmd'l, R.N.Sachthey_and_B.D.Sharma,_for the respondent(inall the appeals). |
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TheJudgment of the Court wasdeliveredby KhnJ.-Th.isit~don1entwould disoose of civilapoeals No.1748to1750_o(_1968filed by special leave against L7J(jS.PCl/7: |
982 SUPilEME COURT REPORTS . }1972] 2 S.C.R. A the judgment of the Calcutta High Court whereby the question referred to that Court under section 66 ( 1 ) of the Indian Incometax Act, 1922, hereinafter referred to as the Act, was answered . in favour of the revenue and against the appellant company. The appellant, a private limited company, was incorporated on January 25, 19~5. The objects for which the Company was B established were given in the clauses of paragraph 3 of the Mem(). randum of Association. A number of business activities were mentioned- in thpse clauses. Clauses 6 and 7 of that paragraph were as under :--:--"6. To purchase take on lease or otherwise .acquire and to hold, cultivate, improve, lease, sell, exchange, C mortgage, or, otherwise, dispose of land, houses, mines, minerals, mining and other real and personal property and to deal with the same commercially. 7. To develop the resources of the same property by building, reclaiming, clearing, draining, and other- D wise improving framing and planting on any terms or system that may be considered advisable." With effect from February 5, 1955, the appellant company took on lease a market place known as TaJ·oUa Bazar in the city of Calcutta from Shrimati Sujata Tagore and her sons on a monthly rent of Rs. 3,000 for a term of 50 years, with option E to the lessee to renew the lea<~e for the further period of 40 years. The deed of lease in this connection was executed on September 5, 1956. Clauses 4, 5 and 13 of the lease deed were as u::der: "4. The Lessee shall have the option to e;.ect, rebuilt, remodel and reconstruct and repair the existing strucF tures upon the demised premises from time to time during the tenn of these presents at its own costs in a substantial and workmanlike manner whh good material of the several kinds in accordance with the plans elevations sanctions and specifications according to the choice of the Lessee (and whenever necesc;arv to get such plans sanctioned by the Corporation of Calcutta) G under the supervic;ion of a first class Engineer to he elected by the Lessee on notice to the Lessors and shall spend upon such works such sum or sumo;; as the Lesc;ee may in its absolute discretion think fit and proper but the entire total sum or sums so to be expended by the Lessee as aforesaid sh::tll not be less than R:upees Five B ( . Lacs and the same shaH be spent within the period of five years from date of these presents. The Lessors shall be at liberty to appoint at their own costs a valuer
S. G. MERCANTILE CORP. v. C.I.T. (Khanna, J.) 983
and surveyor to verify such expenditure if required for their satisfaction after the completion of the said work.
984 SUPREME COURT REPORTS
[1972] z·s.c.P..
| camet.otheconclusionthattheactivitiesoftheappellantcom~ panyintakingtheleaseandsublettingthedemisedpremis~ wereundertakenwiththeobjectofdoing business.TheTribunal observedthatnormallywherethe assessee wasnottheownerof thebuildin_g~teavnedrentbysubletting the same, such income couldonlybechargedundersection 12 as income fromother sources. Thedifficulty, however,aroseincases where letting outofleaseholdpropertywasthebusinessofthe assessee. In suchcases, accordingtotheTribunal,the decisioncouldonly turnuponthe objectforwhich thecompanywas formedand upontheactivitiesofthecompanyduring the relevant accounting· years.Itwasheldthatifthe activityoftheappellantcompany amountedtocarryingonthe businessoftakingonleaseand lettingouttheleasehold property,thecompanywasnotacting asownerbutas trader. Theincome accruingfromsucha source,inthe opinionoftheTribunal,mustbeheldtobeincome frombusiness assessableundersection10oftheAct.TheTri-· bunalaccordinglyheldthattheincomeoftheappellantcom- panyfromsublettingofthe stalls in question wasincomefrom business taxableundersection10oftheAct. Attheinstanceoftheres,!)ondent, theTribunalreferred the followi..<tgquestiontotheHighCourt: "Whether,underthe factsandinthecircumstances ofthe case, the incomefromsubletting the stallsof TaltollaBazarwas assessab1eundersection10orsec tion 12oftheIncome-taxAct,1922?" |
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| Thelearned judgesoftheHighCourtheldthatthe income fromsublettingofthe stalls in questionwasnotassessableunder section10oftheAct.Inarrivingatthisconclusion, the learned judges 0bserved : "Theassesseehadtaken leaseofamarketorBazar. Afterhaving reconstructedorrenovated the buildings, it_is_lettingoutshopsandstallstoshopkeepersand stllholders.Thisisanormalactivityofaownerora lesseeofsucha_marketorBazar.Itcouldnotbesaid thatby lettingoutthe shopsandstallstoshopkeepers •andstallholders, the assessee was carrvingonanyacti- vityinthenatureoftradeandwas utilisingorexploit ing real estateinthe best possible wayorin other words was dealing withitcommercially.Theratioof the SupremeCourtdecision in _EastIndia_Houfif!t _Estate_case(!)isfullvaf}olicabltothecasebefore usanditmustbeheldthattheTribunalwas inerror in its conclusion that lhe incomeofthe assessee-fi6m - 0)[19tllJ 4:'.1T .R ~C>. |
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s. G. MERCANTILE CORP. V. C.I.T. (Khanna, J.) 985
986 SUPREME COURT REPORTS [1972]. 2 S.C.R. A realised from the tenants of shops and stalls was liable to be taxw as business income under section 10 of the Act or income from property under seclion 9. This Court held that the ln.come derived by tne company from shops and stalls was income recei~ ved from property and fell under the specific head described in sec lion 9. it was observed in this connection : B. "Income-tax is urldoubtedly. levied on the total taxable income of the taxpayer and the tax levied is a single tax on the aggregate taxable receipts from all the sources; it is not a collection of taxes separately lev1ed on distinct head$ of income. But the distinct heads specified in secLion 6 indicating the sources are c muually exclusive and income derived from different sources falling under specific heads has to be computed for the purpose of taxaLion in the manner provided by the appropriate section. If the income from a source falls within a specific head set out in section 6, the fact hat it may indirectly be covered by another head D will not make the income taxable under the latter ;head. The income derived by the company from shops and stalls is income received from property and falls under the specific head described in section 9. The character of that income is not' altered because it is received bY a company formed with the object of developing and setting up markets." There is no finding in the present case that the appellant company is the owner of the property in question or any part F' thereof. As such, no reference was made to section 9 of the f Act in the assessment proceedings. The learned counsel for both the parties agree, and in our opinion rightly, that the question of making the assessment against the appellant, in the circumstances under section 9 of the Act does ;not arise. The stand of stand of Mr. Chagla, on behalf of the appellant, is that the assessment G· against the appellant in respect of the income from the property in question should be made under section 10, while according to Mr. Manhanda, learned counsel for· the respondent, the assessment should be under sedon 12 of the Act. Section 10 of the Act deals with in com from business and com~ from business and from business and K
There is no finding in the present case that the appellant company is the owner of the property in question or any part thereof. As such, no reference was made to section 9 of the Act in the assessment proceedings. The learned counsel for both the parties agree, and in our opinion rightly, that the question of making the assessment against the appellant, in the circumstances under section 9 of the Act does ;not arise. The stand of stand of Mr. Chagla, on behalf of the appellant, is that the assessment against the appellant in respect of the income from the property in question should be made under section 10, while according to Mr. Man~handa, learned counsel for· the respondent, the assessment should be under sedon 12 of the Act.
Section 10 of the Act deals with in com~ from business and com~ from business and from business and the material uortion with which we are concerned is given in sub-section ( i) of that section. According to that sub-section, the tax shall be payable by an assessee under the head "Profits
S. G, :MERCANTILE COJlP, l': C.LT. (Khanna, ] . .) 8S7
and gains of uness, profsion. Qr vtion". in ·re&~t of he profits and gains of any busmess, professton or vocaton earned on by him. "Business':, according to section 2(4) ·of the Act, includes any trade, commerce, or manufacture or any adventure or concern in the nature of trade, commerce or manufacture. Section 12 of the Act deals with income from other sources. B Sub-section ( 1) of that section reads as under . :
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" ( 1).Thetaxshallbepayablebyan assesseeunder the head "Income from other sources" in ·respectof income, ·profit and gains of every kind which maybe ipcluded ih his total income(ifnotincluded under any Ofthe precedingheads.), Section 12 deals with the residuary head of incomeand applies to all such taxable income, profits and gains asarenot covered by preceding specific heads.Theresiduary headofin- come can be resorted to onlyifnone of the specific heads is applicable to the income in question;itcomes into operation oruy after the preceding heads are excluded. |
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Itis, therefore, manifest that section12oftheActcanbe invoked in the present case only if we exclude the applicability .of section10by holding that the incomeofthe appellant com- pany from the property in question is not income from business. Thedefinition of the word "Business", asgivnin section2(4) andreproduced above shows its wide amplitudeandwe agree withMr. Chagla that it can embraee within itself dealing inreal property as also the activityoftaking a property on lease, setting upa market thereonandlettingoutthe shopsandstalls in·the market. The important . question which arises in the latter case iswhether the:.acqisitionofthe propertyonleaseandletting out of the shops· and stalls was in the courseofinvestmentor whethritwas essentially a part of thebusinesc;and tra<Jing operationofthe assessee. The · paramount consideration which wouldeighiswhether the acquisition of the property wasby wayof mvestment and whe•her the property was letoutbecause o.ftheassesshavingatitle in the· same?rwhether the acquisi- tion and lettmg outofthe property constttuted the businessand trading activityofthe assessee.Thequestionastowhetherthe above activity is being carriedonby an inrlividualoracom.,anv and in the latter case, the further Q·uestionastowhetherth ..carrying onofthe said activitywa5the objectofthe. incoroora- tio.nofthecompanyasgivninthe MemorandumofAssociation would also have some relevance. Referenceiiithic;context ·may be.madetothe observations·ofLordStem4a}e,M.·R.incase |
| 988 [1972]2S.c.R. |
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| of·Commissioners.of-InlandReven.ue Ltd.(l): v. Korean Syndical~ |
A |
| i· "If.you once get the individual and the company spending exactlyonthe same -basisJ then there would · benodifference between them at all. But the fact thatthe limited company comes into existence in a 'different wayisa matter to be considered.Anindivi- dual comes into existence for many purposesJorper- haps sometimes for noneJ whereas alimitedcompany comesi~to'existence for the particular purposeofcarry- ing out atan actionbygetmg.possessiJnofconces- sions and turning them to accountJ then thatisa matter tobecon.>ideredwhen you come to decide whether doing thatiscarrying on a business or not." |
B |
| ''The·abOveobservations were quoted with approval'bythisCourt in thecaseof_Karanpura Development Co. Ltd.v.Commissioner_ _ofIncome-tax,WestBengale)._The'assessee companyinthe last mentioned case was formed with the objects,_inter alia,_of acquiring and disposing_of_underground coal mining rightsin certaincJa.field>. TheMem::>randum of Association of the company enumerated other objects, suchascoal raising, but the assessee restrictedisactivities to acquiring coal mining leases over large areasJ developing· themascoal fields and then sub- leasing them to collieries and. other companies. · The[easeswere acquired for a termof999 yearsandthe coal fields were sublet for the balance of the term of the respective leases minus two days. Thecompany neverwxkedthe coal fields with a view to raising coal,nordid it acquireorsell coal raisedbythe sub- lessees. As a'!ainsta,salami of Rs.40per bigha which.the asesseehad paid,_it_realised from the sub-lessees Rs. 400per bigha assal-ami. Inddition,the assessee c)larged certain royal;. ties atrteshigher than thoseithad aqreed. to pay u.nder the brad, leases. Thequestion . which arose for determination was whether the amount received bv theassec;seeas salami for grant- ing sub-leaseconstiutdtradngreceipts and the profits there- from was assessable. Itwas held that the tran<:actions of,a.cQuir- ,ing]easesanrie:rantinqsub-leao;eswere in the natureoftrading with;n theobjctsofthe company and not enjoymentofthepro- pertyaslandowner. It_was observed in this connection: "Ashas been already . oointedoutin connection , with the other two cases wnere there is a let•im! out of ' premises and collection of rents_the_assessment on pro- perty,oasismavbecorrectbutn,otso, where the letting . (1)rt92iJ12TaxCas.181. (2)[1962]44 I.T.R.362. |
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S. G. MER.CANnLE COR.P. v. c.r.T. (Khanntl. J.) J.l.
or subletti.DJt is part of a trading operation. The divid· ing line is difficult to find; but in the case of a company wtth its professed objects and the manner of its acti· vities and the nature of its dealins with its property_ it is possible to say on which side the operations fall and to what head the income is to be assined. B Ownership of property and leasing it out may be done as a part of business, or it may be done as landowner. Whether it is the one or the other must necessarily depen.d· upon the object with which the act is done. It rs not that no company can own property and enjoy it as property, wh·ther by itself or by giving 1he use of i'l: to another on rent. Where this happens, tthe appropriate head to apply is "income from property" ( sec'tion 9), even though the company may be doin extensive busine>s othe· wise. But a company formed with the specific object oi acquiring properties not with the view to basing them as propety but to selling them or D turning them to account even by way of leasing them ou as an integral part of its bushes~, cannot be said to treat them as landowner but as trader."
SUPREME OOVRT RBPOJt,T~
9.9.0
·[1972]2 S.C.R.
A .. ,~
| activit}'during .the period of· three years in question consistedof devetopmg, lhe aemised property and letting out ponions of the same as shops, stalls and ground spaces. All the.;e facts point tothe conclusion that thetakinj!;of the property on lease and subletting portions of the same · was part of the business and tradinj!; activityofthe appellant. The conclu.sionofthe Tribunal thattheactivi1ies of the appellant intakinj!;lease and subletting the demised premises were undertaken with the objectofdoing business was warranted on1hefactsof'the case. Likewise, the conclusion of the Tribunal that the aooellant companyinletting outthe leasehold property was not acting as ownerbutastlader was borne out by the materialonrecord. Referenceonbehalf of the respondent has been made by Mr. · Manchandatothe decision of theH.useof Lords in_Frv_v.Salis- bury House Estate Ltd.(1) Inthat case the assessee· company which had been formed to acquire, manage and deal with a block ofbuildl11gs, let out the roomsasunrurnished offices to tenants. Thecompany provide1 a staff to operate the lifts andtoactas porters and watch and protect the bui ding. The c-mpanyal5o provided certainsevices--suchas heating andcleaning-forthe tenants if required,atan additional charge.Forfour years the company was assessed under Schedule Atoincome-lax on the gross value of the building as appearing in the valuationlic;t.The com- pany admitted its liabilitytobeassessed in respect of profits from the service supplied to the tenants under Schedule D,butheCron claimed inmakinthe assessment under Schedule DItoinclude therentsofthe officesaspartof ·thereceipts of trade, making allowance for taxassess•.xlunder SChedule A. It may be men ioned that the-schemeofthe English Income-tax Actisttopovideforthe taxationofspecific properties under schedules appropriatetothem andunder a general ScheduleD.to provide for taxa· ion of income not dealt with specifically. Schedule A provides for the 'taxation of. income derived fromproi>ertv.in land; B (orincom.'!sderived from occupationofland, C for irl'comed·rivedfrom. Government · . securities and E for income from employment in the public ser- . vice.The.Ho\lc;eofLords held inotheabove citeflca"'that·he rents wereP!Ofitsarising from the ownershipoland in respect ofwhichtheassessment under Schedule A was exhaustiveand that thev,' therefore/Could notbeincluded in the assessment under Schedule Dastrade 're'ceiptsofthe company, Theassec:seecom· -pany, in thecitedcase, wastheowner of the SalisburyHouc:.e.and -the decision of the House of Lordsre.c;tedon the view that Sche- -dule A was exhaustive in respectofprofitsaisinafromowne~hil> / ofland. The above decisionisnotofmuch helo to the respan- dentbecause the assessee in the present case is nottheowner (1)·{1930}A.C.432. |
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S. G. MERCANTILE CORP. v. C.I.T. (Khanna. /,)
99l
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A but only a lessee of the prOperty in· question; and section 9, which is anruogou.§ to Schedule A of the English Act, applies to income fwm property consistin~ of buildings orlands appurtenant ~hereto of wtuch the assessee is the owner.
The respondent can also have not much support from the B decision of East India Housing and Land Development Trust ·V'. Commissio11er of Income-tax(!) because what was decided therein was Lhat in the case of income from landed property by the owner company, the income would tall under the spectfic head: described in section 9 and not under section 1 0 even though the company had been· incorporated with the. object of buying and devJloping landed p1 operty and promoting a market thereon. c Section 9, as mentioned earlier, does not apply to the present case because the appellant is not owner of the .property in question. As such there arises no question in this case of the exclu.: sion of seotion 10 on the eround that section 9 is the specifichead. In the instant case the revenue relies not' upon the specifichead given in section 9 but upon the residuary head given in D sectio.n 12 of te Act. It is p1 ain that the considerations which would weigh for applying section 9 on the ground .of being a specific head would not hold good for invoking section 12 which can come into picture only if all the preceding heaqs of income, · including b11siness incom.e as given in section 10, are ruled out. Where, as in the present case, the income can appropriately fall under section 10 as being business income, no resort can be made E to section 12 of the Act.
As a result of the above, we acceot the aooeal and set ac;ide the judgmem of the High Court. The answer to the ques'ion referred by the Tribunal is that the income in ouestion wa~ asc;essabl•.! under section 10 and not under section 12 of the Act. The appellant shall be entitled to 'the costs of this Court as weU as: th0l1e of the Hiah Court. One hearin2 fee.
K.B.N.
Appeal allowed.
(l) [1961]42 I.T.R..~J
1 issue framed by the court
Whether income from subletting stalls of Taltolla Bazar was assessable under section 10 or section 12 of the Income-tax Act, 1922.
Colour shows how this judgement treated each authority
East India Housing and Land Development Trust Ltd. v. Commissioner of Income-taxDistinguished
[1961] 42 I.T.R. 49
Commissioner of Inland Revenue v. Korean Syndicate Ltd.Referred¶42
(1921) 12 Tax Cas. 181
Karanpura Development Co. Ltd. v. Commissioner of Income-tax, West BengalRelied on¶43
[1962] 44 I.T.R. 362
Fry v. Salisbury House Estate Ltd.Distinguished¶56
(1930) A.C. 432
5 provisions across 1 enactments
S.G. Mercantile Corporation (P) Ltd.
Commissioner of Income-tax, Calcutta
J.M. Shelat
I.D. Dua
H.R. Khanna
G.K. Mitter
As recorded by the court registry
Judgements on the same questions, provisions and authorities, from every court
