HON’BLE SUPREME COURT · SOURCE-REVIEWED NOTE
Principal Commissioner of Income Tax 1 Kolkata v M/s Britannia Industries Limited
SLP (C) Diary No. 20632/2026
No separate citation stated in the source ·
56(2)(x) · 43B
Sources & disclosures includedDownload original judgment / order
2 Judges · Pamidighantam Sri Narasimha · Alok Aradhe
01 · Facts of the case
The Revenue sought special leave against a Calcutta High Court judgment involving the statutory interpretation identified in the order. The short record does not set out the underlying transaction or assessment year.
02 · Discussion by the Hon’ble Court
The Court declined interference but expressly left the High Court’s interpretation of section 56(2)(x) coupled with section 43B open for an appropriate case.
Source: paragraphs 3 / PDF pages 1, 2
03 · Judicial decision
Delay was condoned. The special leave petition and pending applications were disposed of with the legal interpretation kept open.
04 · Outcome / in whose favour
In whose favour: Assessee retained the High Court result; legal question expressly open
Delay was condoned. The special leave petition and pending applications were disposed of with the legal interpretation kept open.
No final tax-merits ruling in this order
Source: paragraphs 3-5 / PDF pages 1, 2
05 · AKHB REVIEW POINT
Non-interference here must not be described as the Supreme Court’s approval of the High Court’s statutory reasoning. Keep the precise open-question reservation with the result and do not infer a merits ratio from disposal.
Source: paragraphs 3-5 / PDF pages 1, 2
Source & verification
Download original judgment / order · Open cited source rendition
Complete identified source PDF: 2 pages. Original bytes preserved.
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- Not stated in the reviewed order
Statutory scope
Current statutory equivalence and applicability under the Income-tax Act, 2025 have not been verified.
Later treatment
Source checked 2026-10-04. Subsequent appeals, review proceedings, stays, reversals and later judicial treatment have not been comprehensively checked. This note is not a citator status certificate.
Page references identify the supplied PDF; paragraph references identify the judgment unless stated otherwise.
Identified source links
- official record of proceedings — PDF 2 pages
SHA-256: ba9d9cdc2bee0783f381a537aaea34f9eb7071596b0b95713b2a504b920629f4
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