HON’BLE SUPREME COURT · SOURCE-REVIEWED NOTE
Ranjit Singh v. Commissioner of Income-tax, U.P. and Others
Writ Petition No. 85 of 1959
[1962] 1 SCR 966 ·
Constitution of India: Articles 14 and 32 · Taxation on Income (Investigation Commission) Act, 1947: sections 8 and 8-A · Indian Income-tax Act, 1922: sections 29, 44 and 46
Sources & disclosures includedDownload original judgment / order
5-judge bench; unanimous judgment delivered by S. K. Das, J. · S. K. Das, J. · J. L. Kapur, J. · M. Hidayatullah, J. · J. C. Shah, J. · T. L. Venkatarama Aiyar, J.
Assessment years: Undisclosed income up to 31 March 1947; individual assessment years not specified
01 · Facts of the case
After an Investigation Commission report, Ranjit Singh and family accepted Rs.6,61,917 tax on undisclosed income and offered instalments with acceleration on default. Government accepted the settlement on 21 November 1949 and a demand followed on 2 December 1949. Default led to attachment of family properties. The petitioner sought to stop recovery, arguing that post-Constitution enforcement discriminated against him compared with ordinary Government debtors (SCR pp.967-971; PDF pp.2-6).
Source: Primary judgment: facts
02 · Discussion by the Hon’ble Court
The Court found the settlement, government order and service of demand completed before 26 January 1950, rejecting the unsupported claim of service only in April 1950. Article 14 could not retrospectively invalidate those completed steps. Unlike section 8, section 8-A(2) enforced an accepted settlement without a fresh assessment. The liability remained escaped income-tax, not an ordinary contractual debt; the uniform recovery rules for similarly situated tax-settlement debtors were reasonably related to collection. Earlier invalidation cases concerned discriminatory investigation or settlement after the Constitution and were distinguished (SCR pp.971-977; PDF pp.6-12).
Source: Primary judgment: discussion
03 · Judicial decision
The petition under Article 32 was dismissed with costs. No mandamus restraining the demand or recovery was granted (SCR p.977; PDF p.12).
Source: Primary judgment: decision
04 · Outcome / in whose favour
In favour of Revenue on the constitutional challenge to continued recovery of this completed pre-Constitution settlement; the Court did not revalidate discriminatory post-Constitution investigations or settlements generally (SCR pp.976-977; PDF pp.11-12).
Source: Primary judgment: outcome
05 · AKHB REVIEW POINT
AKHB analysis: distinguish the date and legal nature of investigation, settlement, demand/service and later recovery. Preserve documentary proof of service and separate the validity of the underlying liability from an independent challenge to enforcement. A statutory tax settlement does not become an ordinary contractual debt merely because instalments were agreed; this historical result requires fresh statutory and later-treatment review before present reliance.
Source: Primary judgment: review point
Source & verification
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Statutory scope
Historical 1947 investigation-settlement scheme and pre-Constitution chronology; not a current settlement or recovery-procedure clearance.
Later treatment
Source checked 2026-10-11. Later judicial treatment and current statutory applicability have not been comprehensively checked; no current-law or citator clearance is represented.
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