HON’BLE SUPREME COURT · SOURCE-REVIEWED NOTE
Commissioner of Income-tax, Madras and Another v. S. V. Angidi Chettiar
Civil Appeals Nos. 6-8 of 1961
[1962] Supp. 2 SCR 640 ·
Indian Income-tax Act, 1922: sections 2(9), 23(5), 26A, 28(1)(c), proviso (d) and 44 · General Clauses Act, 1897: section 3(42) · Constitution of India: Article 226
Sources & disclosures includedDownload original judgment / order
5-judge bench; unanimous judgment delivered by J. C. Shah, J. · B. P. Sinha, C.J. · J. L. Kapur, J. · M. Hidayatullah, J. · J. C. Shah, J. · J. R. Mudholkar, J.
Assessment years: 1947-48, 1949-50, 1950-51
01 · Facts of the case
A registered four-person cloth firm concealed income and penalties were imposed after it had allegedly dissolved by agreement or a partner's death. The Madras High Court quashed the orders (SCR pp.641-643; PDF pp.2-4).
Source: Primary judgment: facts
02 · Discussion by the Hon’ble Court
Section 44 continuation machinery covered registered firms; a firm was a person subject to section 28 and proviso (d) supplied the computation basis. Satisfaction had to arise during the underlying proceeding, but notice could follow assessment completion; the record proved timely satisfaction (SCR pp.642-650; PDF pp.3-11).
Source: Primary judgment: discussion
03 · Judicial decision
Revenue's appeals were allowed, the High Court orders set aside and the writ petitions dismissed with costs in both courts, one hearing fee (SCR p.650; PDF p.11).
Source: Primary judgment: decision
04 · Outcome / in whose favour
In favour of Revenue on dissolved-firm reach and timely satisfaction (SCR pp.649-650; PDF pp.10-11).
Source: Primary judgment: outcome
05 · AKHB REVIEW POINT
AKHB analysis: separately test entity reach after dissolution, applicability of the penalty provision and whether jurisdictional satisfaction arose during assessment. The holding permits later notice, not satisfaction first formed later.
Source: Primary judgment: review point
Source & verification
Download original judgment / order · Open cited source rendition
Full 11-page SCR asset read and visually inspected; adjacent-report text after the operative result was excluded.
- Catalogue source S_1962_2_640_650: SHA-256 5bc778ad4702ef8338e4bff124edf831660358229b70a4fe72f0a006ec58f269, 11 pages, read and visually inspected in full.
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- The source verifies identity, bench, provisions, opinion structure and operative order.
- No exact source-hash, asset-ID, SCR-citation, docket or same-judgment publication match was found.
Statutory scope
Repealed 1922 Act firm and penalty machinery; no current-law or citator 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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