HON’BLE SUPREME COURT · SOURCE-REVIEWED NOTE
D. R. Madhavakrishnaiah v Income-tax Officer, Bangalore
Civil Appeals Nos. 209 and 210 of 1953
[1954] SCR 537 ·
Finance Act, 1950, section 13 proviso · Constitution, Articles 245 and 277
Sources & disclosures includedDownload original judgment / order
5-judge bench · Patanjali Sastri CJI (author) · Mehr Chand Mahajan J. · S. R. Das J. · Ghulam Hasan J. · Jagannadhadas J.
Assessment years: Pre-1 April 1950 income; Mysore law through accounting year 1948–49
01 · Facts of the case
The assessee challenged a centrally appointed officer’s jurisdiction to assess earlier Mysore income under the saved Mysore tax law.
Source: Primary report: SCR 538–539
02 · Discussion by the Hon’ble Court
Could Parliament substitute Indian income-tax authorities for State authorities for pre-Constitution periods, despite Article 277? The retrospective legislative-power objection was governed by the accompanying Madan Gopal Kabra decision. Article 277 preserved lawful taxes and their purposes but did not require the same assessing personnel or machinery. Parliament could provide the substituted machinery in section 13.
03 · Judicial decision
Both appeals were dismissed with costs; the officer had jurisdiction.
Source: Primary report: SCR 541
04 · Outcome / in whose favour
Revenue. Both appeals were dismissed with costs; the officer had jurisdiction.
Source: Primary report: SCR 541
05 · AKHB REVIEW POINT
Distinguish preservation of substantive tax liability from continuity of administrative machinery. This is a historical integration and savings ruling, not blanket validation of every retrospective tax measure.
Source: Primary report: SCR 540–541
Source & verification
Download original judgment / order · Open cited source rendition
Five pages / SCR 537–541; last page starts Madan Gopal Kabra, a separate judgment.
Statutory scope
Historical statutory text and assessment period only. Present statutory equivalence and later judicial treatment are not cleared.
Later treatment
Source checked 2026-10-19. Subsequent treatment and current-law applicability have not been comprehensively checked.
Page references identify the supplied PDF; paragraph references identify the judgment unless stated otherwise.
AI disclosure & professional disclaimer
This AKHB research note was prepared with AI assistance from an identified primary report. Independent human review is not represented.
General legal and tax research only; not legal or tax advice. Verify the complete judgment, applicable statutory version and subsequent treatment before reliance. The AKHB REVIEW POINT is editorial analysis, not the Court’s holding. No current-law clearance is claimed.