HON’BLE SUPREME COURT · SOURCE-REVIEWED NOTE
Madhya Pradesh Industries Ltd. v. Income-tax Officer, Nagpur
Civil Appeals Nos. 2419 to 2421 and 2423 to 2425 of 1966
[1971] 1 SCR 266 ·
Indian Income-tax Act, 1922: section 34(1)(a) · Constitution of India: Articles 226 and 227
Sources & disclosures includedDownload original judgment / order
3-judge bench; unanimous judgment delivered by K. S. Hegde, J. · J. C. Shah, J. · K. S. Hegde, J. · A. N. Grover, J.
Assessment years: 1953-54 and connected assessment years
01 · Facts of the case
The company had claimed selling-agent commission and said all material was before the original officer. Later notices asserted escaped income; after the writ challenged jurisdiction, Revenue did not produce the recording, report, sanction or an affidavit from the issuing officer (SCR pp.266-271; PDF pp.1-6).
Source: Primary judgment: facts
02 · Discussion by the Hon’ble Court
The assessee may challenge existence, good faith and rational relevance of the belief, though not adequacy of reasons. Without the issuing officer's evidence or contemporaneous records, the Court had no basis to find the statutory jurisdictional belief (SCR pp.271-274; PDF pp.6-9).
Source: Primary judgment: discussion
03 · Judicial decision
The Court allowed the appeals, set aside the High Court order, quashed the section 34 proceedings and awarded one set of costs (SCR p.274; PDF p.9).
Source: Primary judgment: decision
04 · Outcome / in whose favour
In favour of the assessee: all challenged reassessment proceedings were quashed for unproved jurisdictional foundation (SCR pp.273-274; PDF pp.8-9).
Source: Primary judgment: outcome
05 · AKHB REVIEW POINT
AKHB analysis: preserve and produce the contemporaneous reason record and sanction when jurisdiction is challenged; courts test rational connection, not merits sufficiency. Apply current statutory thresholds separately (based on SCR pp.272-274; PDF pp.7-9).
Source: Primary judgment: review point
Source & verification
Download original judgment / order · Open cited source rendition
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Statutory scope
The ruling applies section 34 of the repealed 1922 Act; current reopening prerequisites, disclosure duties and remedies were not checked.
Later treatment
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