HON’BLE SUPREME COURT · SOURCE-REVIEWED NOTE
Commissioner of Income-tax, Madhya Pradesh v. M/s. Binodiram Balchand, Indore
Civil Appeal No. 27 of 1969
[1970] 3 SCR 328 ·
Income-tax Act, 1922: sections 2(11)(i)(a), 16(2) and 66(1) · Part B States (Taxation Concessions) Order, 1950: paragraphs 3(v), 4, 6 and 12
Sources & disclosures includedDownload original judgment / order
Two-judge bench; judgment delivered by K. S. Hegde, J. · J. C. Shah, J. · K. S. Hegde, J.
Assessment years: 1950-51
01 · Facts of the case
A Hindu undivided family resident in Madhya Bharat received managing-agency income and dividends from Binod Mills. For assessment year 1950-51, the dispute concerned its chosen previous year and the income-tax and super-tax rates applicable to dividend income attributable partly to Part A and partly to Part B State profits (SCR pp.328-331; PDF pp.1-4).
02 · Discussion by the Hon’ble Court
A companion decision established the assessee's right to use the financial year. Because the assessee was a Part B State resident and the income was dividend income from a company registered where no state income-tax law operated, paragraphs 3(v), 4, 6 and 12 of the Concessions Order required the scheduled concessional formula (SCR pp.330-333; PDF pp.3-6).
03 · Judicial decision
The Court upheld the High Court: income-tax on the relevant grossed dividend component and super-tax on the entire dividend income were chargeable at the concessional rates. Revenue's appeal was dismissed with costs.
Source: Primary judgment: decision
04 · Outcome / in whose favour
In favour of the assessee under the historical transitional regime.
Source: Primary judgment: outcome
05 · AKHB REVIEW POINT
AKHB analysis: preserve the Court's sequence - residence, territorial source, character of income and the exact transitional formula. The case is useful for historical reconciliation but must not be cited as a current concession or rate authority.
Source & verification
Download original judgment / order · Open cited source rendition
Complete six-page SCR report read in page-preserving text and every page image inspected.
- Exact catalogue hash and six-page count verified; every page was read and inspected.
- The report verifies assessment year 1950-51, the HUF facts and dismissal with costs.
Statutory scope
The case concerns transitional Part B State concessions and the repealed 1922 Act; it has historical, not current, application.
Later treatment
Source checked 2026-10-12. No present-law application or comprehensive later-treatment review is represented.
Page references identify the supplied PDF; paragraph references identify the judgment unless stated otherwise.
Coverage, AI disclosure & professional disclaimer
Selected Supreme Court income-tax decisions and procedural orders checked against their identified sources. This collection is not exhaustive. The research catalogue has 2,569 indexed PDF assets, including alternate copies and incidental matches; that is not a count of unique or reviewed judgments. Historical and unreported coverage remains open.
AI-assisted research checked against the identified source. Extraction, interpretation or omission errors remain possible. Source review does not mean independent approval by a practising professional. Verify every material statement against the complete original judgment.
General research information only; not legal or tax advice, a certified judgment or a substitute for the full order. Applicability depends on facts, assessment year, statutory version and jurisdiction. Subsequent treatment is unverified unless a note expressly identifies the sources checked. Downloading does not create a professional engagement. Obtain case-specific advice before reliance.
The official 1961–2025 structural correspondence does not establish that a precedent applies under the new Act. Verify the enacted wording, commencement and transitional provisions separately.