{"id":105734,"date":"1980-04-15T00:00:00","date_gmt":"1980-04-14T18:30:00","guid":{"rendered":"https:\/\/www.legalindia.com\/judgments\/anantharam-veerasingaiah-co-vs-commissioner-of-income-tax-a-p-on-15-april-1980"},"modified":"2018-09-24T04:04:11","modified_gmt":"2018-09-23T22:34:11","slug":"anantharam-veerasingaiah-co-vs-commissioner-of-income-tax-a-p-on-15-april-1980","status":"publish","type":"post","link":"https:\/\/www.legalindia.com\/judgments\/anantharam-veerasingaiah-co-vs-commissioner-of-income-tax-a-p-on-15-april-1980","title":{"rendered":"Anantharam Veerasingaiah & Co vs Commissioner Of Income Tax, A.P on 15 April, 1980"},"content":{"rendered":"
Supreme Court of India<\/div>\n
Anantharam Veerasingaiah & Co vs Commissioner Of Income Tax, A.P on 15 April, 1980<\/div>\n
Equivalent citations: 1980 AIR 1146, \t\t 1980 SCR (3) 618<\/div>\n
Author: R Pathak<\/div>\n
Bench: Pathak, R.S.<\/div>\n
           PETITIONER:\nANANTHARAM VEERASINGAIAH & CO.\n\n\tVs.\n\nRESPONDENT:\nCOMMISSIONER OF INCOME TAX, A.P.\n\nDATE OF JUDGMENT15\/04\/1980\n\nBENCH:\nPATHAK, R.S.\nBENCH:\nPATHAK, R.S.\nUNTWALIA, N.L.\nVENKATARAMIAH, E.S. (J)\n\nCITATION:\n 1980 AIR 1146\t\t  1980 SCR  (3) 618\n\n\nACT:\n     Income Tax\t Act,  1961,  Section  271(1)(c),  scope  of\nPenalty Proceedings in quasi judicial and Burden of proof is\non Revenue-Secret  Profits or  undisclosed income  and their\nactual availability for application by the assessee-Power of\nthe High Court in a Tax Reference case, explained.\n\n\n\nHEADNOTE:\n     The appellant,  assessee in  an Abkari  contractor.  It\nfiled a\t return of  its income for the assessment year 1959-\n60, disclosing\ta total\t turnover of  Rs. 10,92,132\/- and an\nincome of Rs. 7,704\/-. The Income Tax Officer did not accept\nthe correctness\t of  the  return.  He  found  that  on\t12th\nDecember,  1957\t  and  16th  January,  1958  the  excess  of\nexpenditure  over  the\tdisclosed  available  cash  was\t Rs.\n17,726\/-  and  Rs.  65,066  respectively.  He  also  noticed\nseveral deposits, totalling Rs. 28,200, entered in the names\nof  certain  Sendhi  shopkeepers.  The\tIncome\tTax  Officer\nrejected  the\taccount\t books\t of  the  assessee  and\t his\nexplanations for the discrepancies thereof and estimated the\nassessee's income  on an  overall figure of Rs. 5,00,018. In\nappeal\tbefore\tthe  Appellate\tAssistant  Commissioner\t and\nthereafter before  the Income  Tax  Appellate  Tribunal\t the\nassessee succeeded in getting the assessed income reduced to\nRs. 1,30,000  in addition  to  the  books  profits.  Penalty\nproceedings were taken against the assessee and the case was\nreferred  to  the  Inspecting  Assistant  Commissioner,\t who\nimposed a  penalty of  Rs. 75,000  under s. 271(1)(c) of the\nIncome Tax  Act,  1961.\t On  appeal  by\t the  assessee,\t the\nAppellate Tribunal  held that there was no positive material\nto establish  that the\tcash deposits  represented concealed\nincome. In  regard  to\tthe  cash  deficits,  the  Appellate\nTribunal noticed  that for  the assessment  year 1957-58  an\naddition of  Rs. 2,00,000 had been made to the book profits,\nand it\tobserved that  some part  of that  amount could have\nbeen ploughed back into the business. It held that an amount\nof Rs. 90,000 representing unledgerised cash credits of that\nyear could  be said  to have  been introduced  in that year.\nAllowing the  appeal, the  Appellate Tribunal  set aside the\npenalty order made by the Inspecting Assistant Commissioner.\n     On a  reference to\t the High  Court, at the instance of\nthe Commissioner of Income Tax, the High Court held that the\nAppellate Tribunal  was not  justified in  holding  that  no\npenalty was leviable. Hence the appeal by special leave.\n     Directing the  Appellate Tribunal to take up the appeal\nunder section 260(1) of the Income Tax Act, the Court\n^\n     HELD: An  order imposing  a penalty  is the  result  of\nquasi criminal\tproceedings. The burden of proof lies on the\nRevenue to  establish that  the disputed  amount  represents\nincome and  that the  assessee has consciously concealed the\nparticulars of\this income  or\thas  deliberately  furnished\ninaccurate particulars. It is for the Revenue to prove these\ningredients before a penalty can be imposed. [622B-C]\n619\n     Since the\tburden of  proof  in  a\t penalty  proceeding\nvaries from  that involved  in an  assessment proceedings  a\nfinding\t in  an\t assessment  proceeding\t that  a  particular\nreceipt is  income cannot  automatically  be  adopted  as  a\nfinding to  that effect\t in the\t penalty proceeding.  In the\npenalty proceeding the taxing authority is bound to consider\nthe matter  afresh on  the material  before it\tand, in\t the\nlight of  the burden  to prove\tresting on  the Revenue,  to\nascertain whether  a particular amount is a revenue receipt.\nNo doubt,  the fact  that the  assessment order\t contained a\nfinding\t that\tthe  disputed\tamount\t represents   income\nconstitutes good  evidence in the penalty proceeding but the\nfinding in  the assessment  proceeding cannot be regarded as\nconclusive for\tthe  purposes  of  the\tpenalty\t proceeding.\nBefore\ta  penalty  can\t be  imposed  the  entirety  of\t the\ncircumstances must  be taken  into account and must point to\nthe conclusion\tthat the  disputed amount  represents income\nand that  the assessee has consciously concealed particulars\nof  his\t  income  or   deliberately   furnished\t  inaccurate\nparticulars. The  mere falsity\tof the\texplanation given by\nthe assessee is insufficient without there being in addition\ncogent\tmaterial   or  evidence\t from  which  the  necessary\nconclusion attracting a penalty could be drawn. [622C-G]\n     Commissioner of  Income Tax,  West Bengal\tand Anr.  v.\nAnwar Ali<\/a>  [1970] 76 I.T.R. 696; Commissioner of Income Tax,\nMadras v.  Khoday Eswara  and Sons,<\/a>  [1972] 83\tI.T.R.\t369;\napplied.\n     2. When  an 'intangible'  addition is  made to the book\nprofits during\tan assessment proceeding, it is on the basis\nthat the amount represented by that addition constitutes the\nundisclosed income  of the  assessee. That  income  although\ncommonly described as 'intangible', is as much a part of his\nreal income  as that  disclosed by his account books. It has\nthe same  concrete existence.  It could\t be available to the\nassessee as the book profits could be. [623A-B]\n     3. Secret\tprofits or undisclosed income of an assessee\nearned in  an earlier assessment year may constitute a fund,\neven though  concealed, from  which the\t assessee  may\tdraw\nsubsequently for  meeting expenditure or introducing amounts\nin his\taccount books.\tAny  part  of  that  fund  need\t not\nnecessarily  be\t  regarded  as\tthe  source  of\t unexplained\nexpenditure incurred  or of  cash credits  recorded during a\nsubsequent assessment  year. The mere availability of such a\nfund cannot,  in all  cases, imply that the assessee has not\nearned further secret profits during the relevant assessment\nyear  It  is  a\t matter\t for  consideration  by\t the  taxing\nauthority,  in\teach  case,  whether  the  unexplained\tcash\ndeficits and  the cash\tcredits can be reasonably attributed\nto a  pre-existing fund\t of concealed  profits or  they\t are\nreasonably explained by reference to concealed income earned\nin that\t very year. In each case the true nature of the cash\ndeficit and  the cash  credit must  be ascertained  from  an\noverall\t consideration\t of   the   particular\t facts\t and\ncircumstances of  the case.  Evidence may exist to show that\nreliance cannot\t be placed completely on the availability of\na  previously\tearned\tundisclosed.  income.  A  number  of\ncircumstances  of   vital  significance\t may  point  to\t the\nconclusion that\t the cash  deficit  or\tcash  credit  cannot\nreasonably  be\t related  to   the  amount  covered  by\t the\nintangible addition  but must be regarded as pointing to the\nreceipt of  undisclosed income\tearned during the assessment\nyear under  consideration. It is open to the Revenue to rely\non all\tthe circumstances  pointing to that conclusion. What\nthose several circumstances can be is difficult to enumerate\nand indeed,  from the  nature of  the enquiry,\tit is almost\nimpossible to  do so. However, they must be such as can lead\nto the firm conclusion that\n620\nthe assessee  has concealed the particulars of his income or\nhas deliberately  furnished inaccurate particulars. [623C-H,\n624A]\n     Lagadapti Subha  Ramiah v.\t Commissioner of Income Tax,\nMadras, [1956]\t30 I.T.R.  593; S.  Kuppuswami\tMudaliar  v.\nCommissioner of\t Income Tax,  Madras, [1964]  51 I.T.R. 757;\napproved.\n     In an income tax reference, a High Court should confine\nitself to  deciding the\t question of  law referred  to it on\nfacts found  by the  Appellate Tribunal. It is the Appellate\nTribunal which has been entrusted with the authority to find\nfacts. [624D-E]\n\n\n\nJUDGMENT:\n<\/pre>\n
     CIVIL APPELLATE  JURISDICTION: Civil Appeal No. 2592 of
\n1972.\n<\/p>\n
     Appeal by\tSpecial Leave  from the\t Judgment and  Order
\ndated 9-11-1971\t of the\t Andhra Pradesh\t High Court  in Case
\nReferred No. 4 of 1970.\n<\/p>\n
     S. T.  Desai, T.  A. Ramachandran, Mrs. J. Ramachandran
\nand M. N. Tandon for the Appellant.\n<\/p>\n
     S. C.  Manchanda, Miss A. Subashini and D. B. Ahuja for
\nthe Respondent.\n<\/p>\n
     The Judgment of the Court was delivered by
\n     PATHAK, J.\t This appeal,  by special leave, is directed
\nagainst\t a  judgment  of  the  Andhra  Pradesh\tHigh  Court,
\nconcerning the\tscope of s. 271(1)(c) of the Income Tax Act,
\n1961.\n<\/p>\n
     The assessee is an Abkari contractor. It filed a return
\nof its\tincome for the assessment year 1959-60, disclosing a
\ntotal turnover\tof Rs. 10,92,132 and an income of Rs. 7,704.
\nThe Income Tax Officer did not accept the correctness of the
\nreturn. He  found that\ton  12th  December,  1957  and\t16th
\nJanuary 1958  the excess  of expenditure  over the disclosed
\navailable cash as Rs. 17,720 and Rs. 650,66 respectively. He
\nalso noticed  several deposits, totaling Rs. 28,200, entered
\nin the\tnames of  certain Sendhi shop-keepers. The assesee’s
\nexplanation that the excess expenditure was met from amounts
\ndeposited with\thim by\tsome shop-keepers but not entered in
\nhis books was not accepted. The alternative explanation that
\nexpenditure incurred  earlier  had  possibly  been  recorded
\nlater was  also rejected.  In regard to the cash deposits of
\nRs. 28,200  the assessee  explained  that  they\t represented
\namounts deposited  with it as security. That explanation was
\nrejected insofar  as  deposits\ttotalling  Rs.\t21,000\twere
\nconcerned. The Income Tax Officer rejected the account books
\nof the\tassessee and  estimated the  assessee’s income on an
\noverall\t figure\t of  Rs.  5,00,018.  In\t appeal\t before\t the
\nAppellate Assistant  Commissioner and  thereafter before the
\nIncome Tax
\n621<\/span>
\nAppellate Tribunal,  the assessee  succeeded in\t getting the
\nassessed income\t reduced to  Rs. 1,30,000 in addition to the
\nbook profits.  Penalty proceeding  were\t taken\tagainst\t the
\nassessee  and  the  case  was  referred\t to  the  Inspecting
\nAssistant  Commissioner.   The\t assessee   reiterated\t the
\nexplanation  which   it\t had   offered\tin   the  assessment
\nproceedings.   Predictably,    the   Inspecting\t   Assistant
\nCommissioner rejected  the explanation\tand  held  that\t the
\nitems  of   cash  deficit   and\t cash  deposits\t represented
\nconcealed income resulting from the suppressed yield and low
\nselling rates  mentioned in  the books. He observed that the
\nassessee had  concealed the  particulars of  his income\t and
\nfurnished inaccurate  of it, and therefore imposed a penalty
\nof Rs. 75,000 under s.271(1)(c) of the Income Tax Act, 1961.
\nOn appeal  by the assessee, the Appellate Tribunal held that
\nthere was  no positive\tmaterial to  establish that the cash
\ndeposits represented concealed income. In regard to the cash
\ndeficits,  the\tAppellate  Tribunal  noticed  that  for\t the
\nassessment year 1957-58 an addition of Rs. 2,00,000 had been
\nmade to\t the book  profits and it observed that some part of
\nthat amount could have been ploughed back into the business.
\nIt  held   that\t an   amount  of   Rs.\t90,000\trepresenting
\nunledgerised cash credits of that year could be said to have
\nbeen introduced\t in this  year.\t Allowing  the\tappeal,\t the
\nAppellate Tribunal  set aside  the penalty order made by the
\nInspecting Assistant Commissioner.\n<\/p>\n
     At the  instance of the Commissioner of Income Tax, the
\nfollowing question was referred to the High Court:-\n<\/p>\n
\t  “Whether on  the facts and in the circumstances of
\n     the case,\tthe Tribunal is justified in holding that no
\n     penalty is leviable ?”<\/p><\/blockquote>\n
     The High Court held that the Appellate Tribunal was not
\njustified in holding that no penalty was leviable.\n<\/p>\n
     In this  appeal, it is urged by learned counsel for the
\nassessee that  the High\t Court erred  in interfering  with a
\nfinding of  fact, that\tthe penalty proceedings being quasi-
\ncriminal the burden of proof lay on the Revenue to establish
\nthat  a\t penalty  was  attracted  and  that  the  intangible
\naddition of  Rs. 2,00,000  represented real  income and\t the
\nAppellate Tribunal  was right  in considering that an amount
\nof Rs. 90,000 was available to cover the cash deficits.\n<\/p>\n
     Section  271(1)(c)\t  of  the   Income  Tax\t  Act,\t1961
\nprovides:-\n<\/p>\n
\t  “271(1).  If\t the  Income   Tax  Officer  or\t the
\n     Appellate Assistant  Commissioner in  the course of any
\n     proceedings  under\t this  Act  is\tsatisfied  that\t any
\n     person-\n<\/p><\/blockquote>\n
\t  (a)\t      *\t\t*\t   *\t     *\n622<\/span>\n\t  (b)\t      *\t\t *\t    *\t     *\n<\/pre>\n
\t  (c)\thas concealed  the particulars of his income
\n\t       or    deliberately    furnished\t  inaccurate
\n\t       particulars of such income he may direct that
\n\t       such person shall pay by way of penalty…
\n\t       …………………”\n<\/p><\/blockquote>\n
This is\t the provision\tas it stood at the relevant time. It
\nis now\tsettled law  that an order imposing a penalty is the
\nresult of quasi-criminal proceeding and that the burden lies
\non  the\t Revenue  to  establish\t that  the  disputed  amount
\nrepresents income  and that  the  assessee  has\t consciously
\nconcealed the  particulars of his income or has deliberately
\nfurnished inaccurate  particulars.  Commissioner  of  Income
\nTax, West  Bengal and  Another v.  Anwar Ali.  It<\/a> is for the
\nRevenue to  prove those\t ingredients before a penalty can be
\nimposed. Since\tthe burden  of proof in a penalty proceeding
\nvaries from  that involved  in an  assessment proceeding,  a
\nfinding\t in  an\t assessment  proceeding\t that  a  particular
\nreceipt is  income cannot  automatically  be  adopted  as  a
\nfinding to  that effect\t in the\t penalty proceeding.  In the
\npenalty proceeding the taxing authority is bound to consider
\nthe matter  afresh on  the material  before it\tand, in\t the
\nlight of  the burden  to prove\tresting on  the Revenue,  to
\nascertain whether  a particular amount is a revenue receipt.
\nNo doubt,  the fact  that the  assessment order\t contains  a
\nfinding\t that\tthe  disputed\tamount\t represents   income
\nconstitutes good  evidence in the penalty proceeding but the
\nfinding in  the assessment  proceeding cannot be regarded as
\nconclusive for\tthe purposes of the penalty proceeding, That
\nis how\tthe law\t has been  understood by this Court in Anwar
\nAli (supra),  and we  believed that  to be the law still. It
\nwas also  laid down that before a penalty can be imposed the
\nentirety of the circumstances must be taken into account and
\nmust point  to\tthe  conclusion\t that  the  disputed  amount
\nrepresents income  and that  the  assessee  has\t consciously
\nconcealed  particulars\t of  his   income  or\tdeliberately
\nfurnished inaccurate  particulars. The\tmere falsity  of the
\nexplanation given  by the  assessee, it\t was  observed,\t was
\ninsufficient without there being in addition cogent material
\nof evidence from which the necessary conclusion attracting a
\npenalty could  be drawn. These principles were reiterated by
\nthis Court  in Commissioner  of Income Tax, Madras v. Khoday
\nEswarsa and<\/a> sons.\n<\/p>\n
     In the  present case, the Appellate Tribunal has relied
\nentirely on  the basic\tthat an\t intangible addition  of Rs.
\n2,00,000 had  been made\t to the book profits of the assessee
\nfor the assessment year 1957-58
\n623<\/span>
\nand it\tinferred that  an amount of Rs. 90,000 was available
\nfor being  put\tto  use\t in  the  year\twith  which  we\t are
\nconcerned.  Now\t it  can  hardly  be  denied  that  when  an
\n“intangible” addition  is made to the book profits during an
\nassessment proceeding,\tit is  on the  basis that the amount
\nrepresented by\tthat addition  constitutes  the\t undisclosed
\nincome\tof  the\t assessee  That\t income,  although  commonly
\ndescribed as  “intangible”, is\tas much\t a part\t of his real
\nincome as  that disclosed  by his  account books. It has the
\nsame concrete  existence.  It  could  by  available  to\t the
\nassessee as  the book  profits could be. In Lagadapati Subha
\nRamiah v.  Commissioner of  Income-tax,\t Madras\t the  Andhra
\nPradesh High Court adverted to this aspect of secret profits
\nand  their   actual  availability  for\tapplication  by\t the
\nassessee. That view was affirmed by the Madras High Court in
\nS. Kuppuswami Mudliar v. Commissioner of Income-Tax, Madras.\n<\/p>\n
     There can\tbe no  escape from  the proposition that the
\nsecret profits\tor undisclosed\tincome of an assessee earned
\nin an  earlier assessment  year may  constitute a fund, even
\nthough\tconcealed,   from  which   the\tassessee   may\tdraw
\nsufficient for meeting expenditure or introducing amounts in
\nhis account books. But it is quite another thing to say that
\nany part  of that  fund must  necessarily be regarded as the
\nsource\tof  unexplained\t expenditure  incurred\tor  of\tcash
\ncredits regarded  during a  subsequent assessment  year. The
\nmere availability of such a fund cannot, in all cases, imply
\nthat the  assessee has\tnot earned  further  secret  profits
\nduring the  relevant assessment\t year. Neither law nor human
\nexperiences  guarantees\t  that\tan  assessee  who  has\tbeen
\ndishonest in  one assessment year is bound to be honest in a
\nsubsequent assessment year. It is a matter for consideration
\nby the taxing authority in each case whether the unexplained
\ncash  deficits\tand  the  cash\tcredits\t can  be  reasonably
\nattributed to  a pre-existing  fund of\tconcealed profits or
\nthey are  reasonably explained\tby  reference  to  concealed
\nincome earned  in that\tvery year.  In each  case  the\ttrue
\nnature of  the cash  deficit and  the cash  credit  must  be
\nascertained from  an overall consideration of the particular
\nfacts and  circumstances of  the case. Evidence may exist to
\nshow that  reliance  cannot  be\t placed\t completely  on\t the
\navailability of\t a previously  earned undisclosed  income. A
\nnumber of  circumstances of  vital significance may point to
\nthe conclusion\tthat the  cash deficit or cash credit cannot
\nreasonably  be\t related  to   the  amount  covered  by\t the
\nintangible addition  but must be regarded as pointing to the
\nreceipt of  undisclosed income\tearned during the assessment
\nyear under  consideration. It is open to the Revenue to rely
\non all the circumstances pointing to
\n624<\/span>
\nthat conclusion.  What those several circumstances can be is
\ndifficult to  enumerate and  indeed, from  the nature of the
\nenquiry, it  is almost impossible to do so. In the end, they
\nmust be\t such as  can lead  to the  firm conclusion that the
\nassessee has  concealed the particulars of his income or has
\ndeliberately  furnished\t  inaccurate  particulars.   It\t  is
\nneedless to  reiterate that  in\t a  penalty  proceeding\t the
\nburden remains\ton the\tRevenue of  proving the\t existing of
\nmaterial leading to that conclusion.\n<\/p>\n
     The Appellate Tribunal erred in law in confining itself
\nto the\tfact that  an intangible  addition had been added to
\nthe assessee’s book profits two years before and that a part
\nof  that   amount  remained   available\t to   the   assessee
\nthereafter, the\t High Court  is right in departing from that
\nlimited approach  and in insisting on a consideration of all
\nthe relevant  facts and\t circumstances of the case relied on
\nby the\tRevenue\t for  purpose  of  determining\twhether\t the
\nRevenue has succeeded in discharging its burden.\n<\/p>\n
     But while\tconsidering the legal principles involved in
\nthe application\t of s.\t271(1)(c) the  High  Court,  in\t our
\nopinion, has  erred in\tentering into  the facts of the case
\nand determining\t in point  of fact  that the assessee earned
\nincome during  the relevant  previous year  and that  he was
\nguilty of  concealing such  income or  furnishing inaccurate
\nparticulars  of\t it.  Having  found  that  the\tlegal  basis
\nunderlying the\torder of  the  Appellate  Tribunal  was\t not
\nsustainable, the  High Court  should have  limited itself to
\nanswering the  question\t raised\t by  the  reference  in\t the
\nnegative, leaving  it to  the Appellate\t Tribunal to take up
\nthe appeal  again and redetermine it in the light of the law
\nlaid down  by the  High Court.\tIt is the Appellate Tribunal
\nwhich has been entrusted with the authority to find facts. A
\nHigh Court  is confined\t to deciding  the  question  of\t law
\nreferred to  it on  facts found\t by the\t Appellate Tribunal.
\nThat is the kind of order we now propose to make.\n<\/p>\n
     Because the  finding of  the Appellate Tribunal that no
\npenalty leviable  rests on  an\terroneous  legal  basis,  we
\nendorse the  opinion of\t the High  Court that  the  question
\nreferred must  be answered  in the negative. But as the High
\nCourt should  not have\trendered findings of fact, we vacate
\nthe finding  of fact  reached by  the  High  Court,  without
\nexpressing any\topinion on  their correctness, leaving it to
\nthe Appellate  Tribunal in  exercise of\t its duty  under  s.
\n260(1) of  the Income  Tax Act\tto take up the appeal and to
\nredetermine it conformably to this judgment and in the light
\nof the principle laid down in it.\n<\/p>\n
     The appeal\t is disposed  of accordingly.  There  is  no
\norder as to costs.\n<\/p>\n
S.R.\t\t\t\t  Case remitted to Tribunal.\n625<\/span>\n\n\n\n<\/pre>\n","protected":false},"excerpt":{"rendered":"
Supreme Court of India Anantharam Veerasingaiah & Co vs Commissioner Of Income Tax, A.P on 15 April, 1980 Equivalent citations: 1980 AIR 1146, 1980 SCR (3) 618 Author: R Pathak Bench: Pathak, R.S. PETITIONER: ANANTHARAM VEERASINGAIAH & CO. Vs. RESPONDENT: COMMISSIONER OF INCOME TAX, A.P. DATE OF JUDGMENT15\/04\/1980 BENCH: PATHAK, R.S. BENCH: PATHAK, R.S. UNTWALIA, […]<\/p>\n","protected":false},"author":1,"featured_media":0,"comment_status":"open","ping_status":"open","sticky":false,"template":"","format":"standard","meta":{"_lmt_disableupdate":"","_lmt_disable":"","_jetpack_memberships_contains_paid_content":false,"footnotes":""},"categories":[30],"tags":[],"class_list":["post-105734","post","type-post","status-publish","format-standard","hentry","category-supreme-court-of-india"],"yoast_head":"\nAnantharam Veerasingaiah & Co vs Commissioner Of Income Tax, A.P on 15 April, 1980 - Free Judgements of Supreme Court & High Court | Legal India<\/title>\n<meta name=\"robots\" content=\"index, follow, max-snippet:-1, max-image-preview:large, max-video-preview:-1\" \/>\n<link rel=\"canonical\" href=\"https:\/\/www.legalindia.com\/judgments\/anantharam-veerasingaiah-co-vs-commissioner-of-income-tax-a-p-on-15-april-1980\" \/>\n<meta property=\"og:locale\" content=\"en_US\" \/>\n<meta property=\"og:type\" content=\"article\" \/>\n<meta property=\"og:title\" content=\"Anantharam Veerasingaiah & Co vs Commissioner Of Income Tax, A.P on 15 April, 1980 - 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