HON’BLE SUPREME COURT · SOURCE-REVIEWED NOTE
A. N. Lakshmana Shenoy v. Income-tax Officer, Ernakulam and Another (and connected appeals)
Civil Appeals Nos. 143–145 of 1954, 27–30 and 161–164 of 1956
[1959] 1 SCR 751 ·
Finance Act, 1950: section 13(1) · Cochin Income-tax Act, 1117: section 44 · Travancore Income-tax Act, 1121: section 47 · Mysore Income-tax Act, 1923: section 34 · Constitution: Articles 278, 295
Sources & disclosures includedDownload original judgment / order
5-judge bench · S. R. Das C.J. · T. L. Venkatarama Aiyar · S. K. Das · A. K. Sarkar · Vivian Bose
Assessment years: Travancore-Cochin assessment years 1123 and 1124 M.E.; connected Mysore pre-integration years
01 · Facts of the case
Eleven appeals challenged reassessment jurisdiction after the integration of Travancore-Cochin and Mysore. In the Shenoy matters, a later assessment disclosed systematic defects extending to earlier years; the taxpayer disputed both the reopening information and survival of the former State laws.
Source: Primary report: SCR 755–766
02 · Discussion by the Hon’ble Court
Definite information must exceed guess or rumour and causally support an honest belief of escaped income; certainty of the eventual liability is unnecessary at notice stage. The later appellate order did not erase all defects. The Finance Act saving of levy, assessment and collection comprehended reassessment. The financial-integration recommendations also preserved proceedings arising out of the earlier laws.
Source: Primary report: SCR 766–777
03 · Judicial decision
Reassessment powers survived under the saved State laws, and the Shenoy notices rested on sufficient information. The Court did not finally determine the constitutional binding force of the financial recommendations because their proper construction supported the proceedings in any event.
Source: Primary report: SCR 777–784
04 · Outcome / in whose favour
The taxpayer’s Travancore-Cochin appeals were dismissed with costs; Revenue’s eight Mysore appeals were allowed and the High Court decisions set aside, with costs in both courts.
Source: Primary report: SCR 785
05 · AKHB REVIEW POINT
Separate the threshold information needed to issue notice from proof of taxable escaped income. For transitional regimes, read the whole saving clause and financial agreement rather than treating completed assessments as immune from expressly saved reassessment.
Source & verification
Download original judgment / order · Open cited source rendition
Complete 35-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.
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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.