HON’BLE SUPREME COURT · SOURCE-REVIEWED NOTE
Raj Kumar Singh Hukam Chandji v. Commissioner of Income-tax, Madhya Pradesh
Civil Appeals Nos. 326 and 327 of 1967
[1971] 1 SCR 748 ·
Indian Income-tax Act, 1922: HUF income principles
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: 1954-55
01 · Facts of the case
The assessee's family owned company shares acquired with family funds, and dividends were credited to the family. The assessee was elected managing director and received salary for personal services (SCR pp.748-755; PDF pp.1-8).
Source: Primary judgment: facts
02 · Discussion by the Hon’ble Court
The controlling test is whether remuneration is substantively a return on family investment or compensation for the coparcener's services. Family qualification shares or opportunity do not change personal-service income where there is no family detriment or investment nexus to the payment (SCR pp.755-760; PDF pp.8-13).
Source: Primary judgment: discussion
03 · Judicial decision
The Court allowed the appeal, answered that the remuneration was the assessee's individual income and awarded costs against the Department (SCR pp.759-760; PDF pp.12-13).
Source: Primary judgment: decision
04 · Outcome / in whose favour
In favour of the assessee: managing-director remuneration was not HUF income (SCR pp.759-760; PDF pp.12-13).
Source: Primary judgment: outcome
05 · AKHB REVIEW POINT
AKHB analysis: document the causal source of remuneration—capital deployment or personal responsibility and skill. A family-funded qualification share is relevant but not conclusive; current law and facts require separate review (based on SCR pp.758-760; PDF pp.11-13).
Source: Primary judgment: review point
Source & verification
Download original judgment / order · Open cited source rendition
Full 13-page SCR source asset read in page-preserving text and visually inspected; adjacent-report boundaries were checked.
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Statutory scope
The ruling applies historical HUF income principles under the repealed 1922 Act; current provisions and later treatment were not checked.
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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