HON’BLE SUPREME COURT · SOURCE-REVIEWED NOTE
Ravula Subba Rao and another v. Commissioner of Income-tax, Madras
Civil Appeals 56 and 57 of 1954
[1956] 1 SCR 577 ·
Income-tax Act 1922, sections 26A, 59 · Income-tax Rules, rules 2 and 6 · Powers-of-Attorney Act 1882, section 2
Sources & disclosures includedDownload original judgment / order
3-judge bench · S. R. Das C.J. · Bhagwati · Venkatarama Ayyar
Assessment years: 1943–44 and 1944–45
01 · Facts of the case
One partner signed renewal applications both for himself and as attorney of a partner away on pilgrimage. The rules required personal signatures, and renewal was refused.
Source: Primary report: SCR 578–580
02 · Discussion by the Hon’ble Court
Registration was a statutory benefit subject to the Act’s prescribed conditions. Its scheme displaced general agency rules for this application. The authority to prescribe applicants, form and verification authorized rules 2 and 6. Powers-of-Attorney Act section 2 validates the manner of exercising existing authority; it does not create authority where personal action is required.
Source: Primary report: SCR 580–590
03 · Judicial decision
Rules requiring each partner’s personal signature were intra vires; signature by an agent did not comply. Appeals dismissed with costs.
Source: Primary report: SCR 590–591
04 · Outcome / in whose favour
Revenue succeeded.
Source: Primary report: SCR 590–591
05 · AKHB REVIEW POINT
Distinguish authority to act from the form of an authorized agent’s signature. This decision concerns the then statutory firm-registration benefit and cannot be transplanted without examining later law and exceptions.
Source: Primary report: SCR 588–591
Source & verification
Download original judgment / order · Open cited source rendition
Complete 15-page Supreme Court Reports scan. Any adjoining report fragments remain in the unchanged original and are excluded from this analysis.
Statutory scope
Historical legislation expressly identified in this note. This is not a decision under the Income-tax Act, 1961 or the Income-tax Act, 2025. Verify enacted wording, commencement, transition and subsequent judicial treatment independently before modern reliance.
Later treatment
Source checked 2026-10-23. Subsequent treatment and present-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
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General legal and tax research only; not legal or tax advice. Verify the complete judgment, applicable statutory version and subsequent treatment before reliance. AKHB REVIEW POINT is editorial analysis, not the Court’s holding.