HON’BLE SUPREME COURT · SOURCE-REVIEWED NOTE
Rajah S. V. Jagannath Rao v. Commissioner of Income-tax, Hyderabad
Civil Appeals Nos. 1661-68 of 1959 (as printed in the SCR report)
[1962] 2 SCR 848 ·
Hyderabad Income-tax Act, 1357 Fasli: sections 2(4) and 14(5)(a)-(c) · Hyderabad Legislative Assembly Ain: section 18(8)-(9)
Sources & disclosures includedDownload original judgment / order
3-judge bench; unanimous judgment delivered by M. Hidayatullah, J. · S. K. Das, J. · M. Hidayatullah, J. · J. C. Shah, J.
Assessment years: 1357 Fasli (1948-49), 1358 Fasli (1949-50)
01 · Facts of the case
The Jagirdar of Jatprole challenged the Hyderabad income-tax law, its taxation of 1356 Fasli income, and rejection of estate-expense claims of Rs.14,390 and Rs.38,079 for assessment years 1357 and 1358 Fasli. The High Court had answered all three questions against him (SCR pp.849-851, 854-855; PDF pp.2-4, 7-8).
Source: Primary judgment: facts
02 · Discussion by the Hon’ble Court
The Nizam's assent gave the historical enactment binding force; the Ain was not a superior constitution limiting his then sovereignty. The prior-year-income issue was covered by earlier decisions and was not pressed. Under section 14(5)(a), occasional administrative use of estate equipment could establish the required connection; a sanad compelling the expense was unnecessary. Drummers, elephants, stables and bodyguards qualified, but domestic servants, festivals, jatras, charities and subscriptions did not (SCR pp.851-858; PDF pp.4-11).
Source: Primary judgment: discussion
03 · Judicial decision
Appeals were allowed in part. The third answer was replaced to allow Rs.26,057 for 1358 Fasli and the qualifying amount to be determined from the Rs.14,390 claim for 1357 Fasli. The first two answers stood; each party bore its own Supreme Court costs (SCR p.858; PDF p.11).
Source: Primary judgment: decision
04 · Outcome / in whose favour
Partial success for the assessee on specified administration expenses; Revenue succeeded on validity and assessment of the earlier accounting-year income (SCR pp.851, 854, 858; PDF pp.4, 7, 11).
Source: Primary judgment: outcome
05 · AKHB REVIEW POINT
AKHB analysis: separate each expense item, the statutory nexus and its personal component. A mixed claim cannot be treated as wholly deductible merely because some equipment serves administration. The ruling applies the historical Hyderabad provision and supplies no present-law clearance for similar spending.
Source: Primary judgment: review point
Source & verification
Download original judgment / order · Open cited source rendition
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Statutory scope
Historical Hyderabad sovereign-legislative setting and the 1357 Fasli Act; not current constitutional or general deduction guidance.
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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