HON’BLE SUPREME COURT · SOURCE-REVIEWED NOTE
P. V. Raghava Reddi and Another v. Commissioner of Income-tax
Civil Appeals Nos. 325 and 326 of 1960
[1962] Supp. 2 SCR 596 ·
Indian Income-tax Act, 1922: sections 4(1)(a), 4(1)(c), 18, 40, 42 and 43
Sources & disclosures includedDownload original judgment / order
5-judge bench; unanimous judgment delivered by M. Hidayatullah, J. · B. P. Sinha, C.J. · J. L. Kapur, J. · M. Hidayatullah, J. · J. C. Shah, J. · J. R. Mudholkar, J.
Assessment years: 1949-50, 1950-51
01 · Facts of the case
The Gudur mica exporter retained a non-resident Japanese agent. Exchange controls prevented remittance, so commission included in Indian receipts was credited to a separate account under the agent's instructions and held subject to its directions (SCR pp.598-600; PDF pp.3-5).
Source: Primary judgment: facts
02 · Discussion by the Hon’ble Court
The business connection supported statutory agency. Section 4(1)(a) independently reached actual receipt. After contractual credit the firm held segregated funds as depositee for the Japanese company and at its disposal; actual directions over part confirmed control (SCR pp.600-605; PDF pp.5-10).
Source: Primary judgment: discussion
03 · Judicial decision
The appeals were dismissed with costs and one hearing fee; the High Court answer for Revenue stood (SCR p.605; PDF p.10).
Source: Primary judgment: decision
04 · Outcome / in whose favour
In favour of Revenue on agency and Indian receipt (SCR pp.600-605; PDF pp.5-10).
Source: Primary judgment: outcome
05 · AKHB REVIEW POINT
AKHB analysis: distinguish a unilateral book entry from contractual appropriation where segregated funds are immediately available to the non-resident's instructions. Document mandate, control and actual directions.
Source: Primary judgment: review point
Source & verification
Download original judgment / order · Open cited source rendition
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- The source verifies identity, bench, provisions, opinion structure and operative order.
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Statutory scope
Historical receipt, statutory-agent and exchange-control setting; no current sections 5, 9, 195 or treaty 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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