{"id":243761,"date":"1986-10-13T00:00:00","date_gmt":"1986-10-12T18:30:00","guid":{"rendered":"https:\/\/www.legalindia.com\/judgments\/commissioner-of-income-tax-vs-maharaja-bahadur-singh-ors-on-13-october-1986"},"modified":"2015-02-11T20:24:38","modified_gmt":"2015-02-11T14:54:38","slug":"commissioner-of-income-tax-vs-maharaja-bahadur-singh-ors-on-13-october-1986","status":"publish","type":"post","link":"https:\/\/www.legalindia.com\/judgments\/commissioner-of-income-tax-vs-maharaja-bahadur-singh-ors-on-13-october-1986","title":{"rendered":"Commissioner Of Income-Tax, … vs Maharaja Bahadur Singh & Ors on 13 October, 1986"},"content":{"rendered":"
Supreme Court of India<\/div>\n
Commissioner Of Income-Tax, … vs Maharaja Bahadur Singh & Ors on 13 October, 1986<\/div>\n
Equivalent citations: 1987 AIR 518, \t\t 1986 SCR (3)1020<\/div>\n
Author: R Pathak<\/div>\n
Bench: Pathak, R.S.<\/div>\n
           PETITIONER:\nCOMMISSIONER OF INCOME-TAX, MADHYA PRADESH\n\n\tVs.\n\nRESPONDENT:\nMAHARAJA BAHADUR SINGH & ORS.\n\nDATE OF JUDGMENT13\/10\/1986\n\nBENCH:\nPATHAK, R.S.\nBENCH:\nPATHAK, R.S.\nMUKHARJI, SABYASACHI (J)\n\nCITATION:\n 1987 AIR  518\t\t  1986 SCR  (3)1020\n 1986 SCC  (4) 512\t  JT 1986   648\n 1986 SCALE  (2)591\n\n\nACT:\n     Income Tax\t Act, 1961-Income  derived by  beneficiaries\nunder Trust  Deeds-Income derived in individual capacity and\nnot as\trepresenting HUF-Assessment  of Income-Determination\nof.\n\n\n\nHEADNOTE:\n     One Hukum\tChand Seth,  who constituted  a HUF with the\nmembers of  his\t family,  owned\t extensive  properties.\t The\nproperties were\t partitioned between him, his wife and their\nson in\tequal shares  by a Deed of Partition dated March 31,\n1950. On  the same  date, Hukum\t Chand\tSeth  and  his\twife\nexecuted two  trust deeds  nominating  their  son  and\tfive\ngrandsons as the beneficiaries in respect of their shares in\nthe aforesaid  properties. The\ttrust deeds  which contained\nidentical terms inter alia provided (a) that in the event of\na beneficiary  dying before  the time of distribution of the\nproperties between  the\t beneficiaries,\t the  share  of\t the\nbeneficiary so\tdying would  be used to support and maintain\nhis widow  and his male issue in such manner as the trustees\nshall \"in  their absolute  and uncontrolled  discretion deem\nproper\" and  the surplus,  if any,  of\tthe  share  of\tthat\nbeneficiary and\t the income  therefrom would  be accumulated\nand kept  in credit to his account and preserved in order to\nbe  distributed;   (b)\tthat   upon  the   youngest  of\t the\nbeneficiaries attaining\t the age  of 30\t years, the trustees\nwould divide  and distribute  the trust\t properties together\nwith the  accumulated interest\tand income thereon among the\nbeneficiaries  according  to  their  respective\t rights\t and\nshares; and  (c) that  if at  the time\tof the\tdivision and\ndistribution  any   beneficiary\t should\t have  died  without\nleaving any  son but  leaving only  a widow, the widow would\nget half  of the  share of  that beneficiary while the other\nhalf would  be distributed among the remaining beneficiaries\nand the heirs of the beneficiaries entitled to distribution.\n     With the  passage of  time the  beneficiaries came into\npossession of  their respective shares of the properties and\nthe income  from those\tproperties was\treturned by them for\nthe purpose of their income tax\n1021\nassessment in their individual status, but subsequently they\nbegan to assert that the properties were received by them as\nthe Karta  of their  respective Hindu undivided families and\nthat therefore\tthe income was liable to be assessed in that\nstatus.\t The   Income  Tax   Officer,  during  the  relevant\nassessment years  assessed  the\t assessees\/beneficiaries  in\ntheir individual status and these assessments were confirmed\nby the\tAppellate Assistant  Commissioner and the Income Tax\nAppellate Tribunal.  However, in a reference at the instance\nof the\tassessees, the\tHigh Court  held that the properties\nhad been  settled with the assessees in their representative\ncapacity as  Kartas  of\t their\trespective  Hindu  undivided\nfamilies.\n     Allowing the appeals by the Revenue to this Court,\n^\n     HELD 1.1  The High Court has erred in the view taken by\nit of  the two\ttrust deeds. The question whether the income\nbelongs to  the individuals  or Hindu undivided families has\nto be  resolved upon  the contents of the trust deeds, their\nterms and  conditions being  free  from\t ambiguity.  [1028D;\n1026F]\n     1.2  Where\t  the  document\t  contains  no\tclear  words\ndescribing the\tkind of interest which the donee is to take,\nthe question  is one  of construction  and  the\t court\tmust\ncollect the  intention of the donor from the language of the\ndocument taken\talong with  the\t surrounding  circumstances.\nThere is no presumption one way or the other. Each case must\nbe decided  on its own facts and each document calls for its\nown particular construction. [1026H; 1027A-B]\n     C.N. Arunachala  Mudaliar v.  C.A. Muruganatha Mudaliar\nand Another,<\/a> [1954] 5 SCR 243, referred to.\n     In the  instant case,  on the  plain terms of the trust\ndeeds, the  properties\twere  intended\tto  devolve  on\t the\nbeneficiaries in their individual capacity. The circustances\nsurrounding the execution of the two documents indicate that\na common  intention inspired  the minds of the two settlors.\nThis has  considerable significance when it is realised that\nwhile one  trust deed  was executed  by a male member of the\nfamily the  other was  executed by  a female  member of\t the\nfamily. The  course of\tdevolution under the Hindu law would\nbe materially different in the two cases and, therefore, the\nprinciples of  the Hindu  law governing\t the  devolution  of\nproperty in  the case  of property  passing from a father to\nhis son\t and grandsons\tcannot be  invoked in these appeals.\n[1027B-C]\n1022\n     2. The  terms and\tconditions of  the trust  deeds\t are\nwholly inconsistent with the property passing into the hands\nof the\tbeneficiaries as  Kartas of  their respective  Hindu\nundivided families.  There is  clear indication in the trust\ndeeds which  bears this out. In the first place, had it been\nintended that the beneficiary should receive the property as\nKarta of  his Hindu  undivided family the document would not\nhave empowered\tthe trustees,  in clause  1 to\texercise  an\nabsolute and  uncontrolled discretion  on  the\tdeath  of  a\nbeneficiary to\tapply his  share to  the maintenance  of his\nwidow and  his male  issue and\tto accumulate the surplus to\nthe account of the said beneficiary for distribution. On the\ncontrary, the  trustees would  have been under an obligation\nto entrust  the income\tfalling to the share of the deceased\nbeneficiary to the members of his Hindu Undivided family and\nno discretion  would have  been permissible in regard to the\ndisposal or  otherwise of  any part  thereof. Secondly,\t the\ndocument would\tnot have provided that if before the time of\ndivision and  distribution a  beneficiay died leaving only a\nwidow, the  widow would get a half of the share belonging to\nthe deceased  beneficiary while\t the  other  half  would  be\nliable to  distribution among  the remaining  beneficiaries.\nThese two conditions are sufficient in themselves to lead to\nthe  conclusion\t  that\tit   was  never\t intended  that\t the\nproperties should  pass to  the beneficiaries  to be held by\nthem for  their respective Hindu undivided families. [1027D-\nH]\n\n\n\nJUDGMENT:\n<\/pre>\n
     CIVIL APPELLATE JURISDICTION: Civil Appeal Nos. 1681-84
\nof 1974.\n<\/p>\n
     From the  Judgment and Order dated 1\/6th February, 1974
\nof the\tMadhya Pradesh\tHigh Court  in Civil Cases Nos. 240,
\n238 and 239 of 1971.\n<\/p>\n
     M.K. Banerjee,  Additional Solicitor  General,  Ms.  A.
\nSubhashini and B.B. Ahuja for the Appellant.\n<\/p>\n
     S.T. Desai,  A.K. Chitale,\t Mrs. S.  Gambhir  and\tS.K.
\nGambhir for the Respondents.\n<\/p>\n
     The Judgment of the Court was delivered by
\n     PATHAK, J.\t These appeals by special leave are directed
\nagainst the  common judgment  of the  High Court  of  Madhya
\nPradesh\t disposing   of\t four\tIncome-tax  References\t and
\nanswering the following identical question of law arising in
\neach Reference\tin favour  of the  assessee and\t against the
\nRevenue:\n<\/p>\n
1023<\/span><\/p>\n
\t  “Whether on  the facts and in the circumstances of
\n\t  the case,  the Tribunal  was justified  in law  in
\n\t  holding   that   the\t income\t  derived   by\t the
\n\t  beneficiaries under  the two\ttrust-deeds belonged
\n\t  to the  beneficiary in individual capacity and not
\n\t  in  the   capacity  as   representing\t the   Hindu
\n\t  undivided family?”\n<\/p><\/blockquote>\n
     These appeals  involve the\t construction of  two trust-\n<\/p><\/blockquote>\n
deeds couched in identical terms. To understand their import
\nit is necessary to set out a genealogical table:\n<\/p>\n
\t\tSir Hukumachand Seth (Karta)
\n\t\t\t     m
\n\t\t   Lady Kanchanbai (Wife)
\n\t\t  Shri Rajkumarsingh (Son)
\n\t\t\t     m
\n\t\tSmt. Premkumari Devi (Wife)
\n____________________________________________________________
\nRaj Bahadur   Maharaj Bahadur\tJambukumar   Ch. Kumar\tYesh
\nSingh(son)   Singh (son)       Singh (son)  Singh      Kumar
\n\t\t\t\t\t\t       Singh
\n__________   _______________   ____________
\n  m\t       m\t\t   m\t    (Minor)  (Minor)
\nSmt.Indrani   Smt.Sneha Lata   Smt.Urmila
\nDevi (wife)   Devi (wife)      Devi (wife)
\n__________    _____________    ___________
\nPravin Dhir- Naina  Sunaina    Pramod Kumar (son)
\nKumar  rendra Kumari Kumari
\n(son)  (son)\t(Daughter)
\n     Sir Hukumchand Seth was the head of a well known family
\nof Indore.  The family\tcarried on  various  businesses\t and
\nowned extensive\t properties. Prior  to March  31,  1950\t Sir
\nHukum Chand  and the  members of  his family  constituted  a
\nHindu Undivided\t family. By  a deed of partition dated March
\n31, 1950  various family properties were partitioned between
\nSir Hukum  Chand, his wife Lady Kanchanbai and their son Raj
\nKumar Singh  in equal  shares.\tSir  Hukum  Chand  and\tLady
\nKanchanbai executed  two trust deeds on the same date, March
\n21, 1952  purporting to constitute a trust of the properties
\nrespectively belonging\tto them.  The trust  deeds contained
\nidentical terms\t and conditions.  The trustees\tin each case
\nwere Sir  Hukum Chand,\tLady Kanchanbai, their son Raj Kumar
\nSingh and his wife Prem Kumari
\n1024<\/span>
\nDevi  and  the\teldest\tgrandson  Raja\tBahadur\t Singh.\t The
\nbeneficiaries named  in the  trust deeds were Rajkumar Singh
\nand his\t sons Raja  Bahadur Singh,  Maharaja Bahadur  Singh,
\nJambukumar Singh,  Chandrakumar Singh  and Yeshkumar  Singh.\n<\/p><\/blockquote>\n
With the  passage of  time and\tin accordance with the terms
\nand conditions\tof the\ttrust deeds  the beneficiaries\tcame
\ninto  possession   of  their   respective  shares   of\t the
\nproperties. Originally\tthe income from those properties was
\nreturned  by  them  for\t the  purpose  of  their  income-tax
\nassessments in\ttheir individual  status,  but\tsubsequently
\nthey began  to assert  that the\t properties were received by
\nthem as\t the  Karta  of\t their\trespective  Hindu  undivided
\nfamilies and  that, therefore,\tthe income  was liable to be
\nassessed in that status.\n<\/p>\n
     These appeals  arise out of income tax assessments made
\nin the\tcase of\t Raja Bahadur  Singh for the assessment year
\n1962-63, Maharaja  Bahadur Singh  for  the  assessment\tyear
\n1961-62 and  Jambukumar Singh for the assessment years 1961-
\n62 and\t1962-63. The  Income Tax  Officer assessed all three
\nassessees in  their individual\tstatus and  the\t assessments
\nwere confirmed\tin that\t status by  the Appellate  Assistant
\nCommissioner on\t appeal. On  second appeal  by the assessees
\nthe Income  Tax Appellate  Tribunal also  took the view that
\nthe income  from the  properties received  by the  assessees
\nunder the  two\ttrust  deeds  fell  to\tbe  taxed  in  their
\nindividual status.  At the  instance of\t the  assessees\t the
\nAppellate Tribunal  referred the  cases to the High Court of
\nMadhya Pradesh\tfor its opinion in each case on the question
\nof law\tset forth earlier. The High Court understood the two
\ntrust deeds  differently from the Appellate Tribunal and the
\ntaxing authorities  and held  that the\tproperties had\tbeen
\nsettled with  the assessees in their representative(capacity
\nas Kartas of their respective Hindu undivided families.\n<\/p>\n
     It may  be mentioned  at the  outset that\tneither\t the
\nassessees nor  the Revenue dispute the legality of the trust
\ndeeds and we must proceed on the assumption, as did the High
\nCourt, the  Appellate Tribunal\tand the\t taxing authorities,
\nthat the authors of the trust deeds were competent to settle
\nthe properties\tin accordance  with the terms and conditions
\nexpressed in those documents.\n<\/p>\n
     The sole question before us is whether upon those terms
\nand conditions\tit was\tintended by  the settlors  that\t the
\nbeneficiaries  should\treceive\t the   properties  in  their
\nindividual capacity  or\t in  a\trepresentative\tcapacity  as
\nKartas of the respective Hindu undivided families. It is not
\nnecessary to  refer to all the provisions of the trust deeds
\nbecause the
\n1025<\/span>
\nparties\t are   in  common   agreement  that   the  principal
\nprovisions calling  for consideration are clauses 1, 3 and 4
\nof the\ttrust deeds. Clause 1 empowers the trustees to apply
\nthe income  from the  trust properties\tto the\trent, rates,
\ntaxes  and   other  liabilities\t in  respect  of  the  trust
\nproperties,  including\t the  cost   of\t  maintenance,\t and
\nthereafter to  divide the  balance left over in equal shares
\nbetween the beneficiaries, so that each beneficiary received
\none-sixth of  the balance.  In the  event of  a\t beneficiary
\nbeing a\t minor, his  share of  the income was payable to his
\nnatural guardian  for being  applied towards  his education,
\nmaintenance and\t advancement in\t life,\tmarriage  and  other
\nexpenses. It  was also\tprovided that  in  the\tevent  of  a
\nbeneficiary dying  before the  time of\tdistribution of\t the
\nproperties between  the beneficiaries  under clause  4,\t the
\nshare of  the beneficiary  so dying would be used to support
\nand maintain his widow and his male issue “in such manner as
\nthe  trustees  shall  in  their\t absolute  and\tuncontrolled
\ndiscretion deem\t proper” and  the surplus,  if any,  of\t the
\nshare of  that beneficiary and the income therefrom would be
\naccumulated and\t kept in credit to his account and preserved
\nin order  to be\t distributed in accordance with clause 4. In
\nthe  event  of\ta  beneficiary\tdying  before  the  time  of
\ndistribution without  leaving any  widow or  male issue\t his
\nshare was  to be  divided equally  among other beneficiaries
\nthen alive  or the  then widow\tand male  issue of any other
\ndeceased beneficiary,  if any,\tentitled  to  share  in\t the
\ndistribution, subject,\thowever, to provision being made for
\nthe  maintenance   and\teducation  until  marriage  and\t the
\nmarriage expenses  of the  daughter or\tdaughters, if any of
\nthe said  beneficiary. Clause  3 declares that if any moneys
\nwere required  for meeting  extraordinary expenses of or for
\nthe benefit  of any  beneficiary or  his wife or children on
\nspecial occasions,  such as  the marriage of the beneficiary
\nand of\this children,  the illness  of the beneficiary or of
\nhis children,  travelling expenses of the beneficiary and of
\nhis family  for going  abroad, their  education in a foreign
\ncountry or  on such other occasions as the trustees may deem
\nfit for\t special treatment,  the trustees  were empowered to
\npay to\tthe beneficiary\t such amounts  from time  to time as
\nthey thought  fit in their absolute discretion. Such amounts
\ncould be paid to the beneficiary out of the trust properties
\neither by  way of  advance or loan either on interest or out
\nof his share of the corpus. In the latter event the share of
\nthe net\t income payable\t to the\t beneficiary was  liable  to
\nproportionate reduction.  Clause 4  provides that  upon\t the
\nyoungest of  the beneficiaries attaining the age of 30 years
\nthe  trustees\twould  divide\tand  distribute\t  the  trust
\nproperties together with the accumulated interest and income
\nthereon\t among\t the  beneficiaries   according\t  to   their
\nrespective rights and shares, that is to say equally,
\n1026<\/span>
\nand in\tmaking such  division the  trustees would  take into
\nconsideration the  amount due  by  the\tbeneficiary  to\t the
\ntrustees by  way of  loan or  advance made  to him.  It\t was
\nfurther provided  that if  any beneficiary  should have died
\nbefore the  time of  such division or distribution leaving a
\nwidow and  any son  or sons  or only  son or  sons the widow
\nand\/or the  sons would\ttake by substitution the share which
\nthe beneficiary would have taken had he been alive, and such
\nshare would  be divided\t equally between  the widow  and the
\nsons. The  proviso declares  that if  at  the  time  of\t the
\ndivision and  distribution any\tbeneficiary should have died
\nwithout leaving\t any son but leaving only a widow, the widow
\nwould get  half of  the share  of that beneficiary while the
\nother  half   would  be\t  distributed  among  the  remaining
\nbeneficiaries and the heirs of the beneficiaries entitled to
\ndistribution. A\t further provision  declares that  if at the
\ntime of\t division and  distribution any\t beneficiary  should
\nhave died  without leaving a widow or a son his share would,
\nsubject to  such adequate provision made for the maintenance
\nand education  until marriage  and the\tmarriage expenses of
\nthe  daughter  or  daughters  of  such\tbeneficiary  as\t the
\ntrustees may  in their\tdiscretion think fit, he distributed
\namong the  remaining beneficiaries  and\t the  heirs  of\t the
\nbeneficiaries entitled to distribution.\n<\/p>\n
     The assesses filed a declaration dated October 19, 1964
\nthat on\t and from Diwali 1959 the income accruing to them as
\nbeneficiaries from the two trust deeds should be regarded as
\nincome belonging to their Hindu undivided families. The High
\nCourt and  the Appellate  Tribunal have\t rightly  held\tthat
\nthose subsequent  declarations\tcan  be\t of  no\t moment\t for
\ndeciding whether  the income  belonged to the individuals or
\ntheir Hindu  undivided families.  It is\t settled by law that
\nthe question  has to  be resolved  upon the  contents of the
\ntrust deeds,  their terms  and conditions  being  free\tfrom
\nambiguity. The\tquestion whether  a gift of self-acquired or
\nseparate property  by a father to his son results in the son
\nholding it  as ancestral  property was\tconsidered  by\tthis
\nCourt  in  C.N.\t Arunachala  Mudaliar  v.  C.A.\t Muruganatha
\nMudaliar and  Another,<\/a> [1954]  5 S.C.R. 243, and it was laid
\ndown that it was perfectly competent for the father, when he
\nmakes a\t gift, to  provide expressly  either that  the donee
\nwould take it exclusively for himself or that the gift would
\nbe for the benefit of the branch of his family, and if there
\nare express provisions to that effect in the deed of gift or
\nwill, the interest which the son would take in such property
\nwould depend upon the terms of the grant. Where the document
\ncontains no  clear words  describing the  kind\tof  interest
\nwhich  the  donee  is  to  take,  the  question\t is  one  of
\nconstruction and the Court must collect the intention of the
\n1027<\/span>
\ndonor from the language of the document taken along with the
\nsurrounding circumstances.  There is  no presumption one way
\nor the\tother. It  is not  necessary for  us to refer to the
\nseveral cases  cited before  us, because  each case  must be
\ndecided on its own facts and each document calls for its own
\nparticular construction.\n<\/p>\n
     The circumstances\tsurrounding the execution of the two
\ndocuments indicate  that a  common  intention  inspired\t the
\nminds  of   the\t two   settlors.   This\t  has\tconsiderable
\nsignificance when  it is  realised that while one trust deed
\nwas executed  by a  male member\t of the family the other was
\nexecuted by  a female  member of  the family.  The course of
\ndevolution under the Hindu law would be materially different
\nin the two cases and, therefore, the principles of the Hindu
\nlaw governing  the devolution  of property  in the  case  of
\nproperty passing  from a  father to  his son  and  grandsons
\ncannot be invoked in these appeals.\n<\/p>\n
     Even if  the matter  be looked at in the context of the
\nHindu law as it obtained at the relevant time, the terms and
\nconditions of  the trust  deeds are wholly inconsistent with
\nthe property  passing into the hands of the beneficiaries as
\nKartas of  their respective  Hindu undivided families. There
\nis clear indication in the trust deeds which bears this out.
\nIn  the\t  first\t place,\t  had  it  been\t intended  that\t the
\nbeneficiary should  receive the\t property as  Karta  of\t his
\nHindu undivided family the document would not have empowered
\nthe trustees,  in clause  1, to\t exercise  an  absolute\t and
\nuncontrolled discretion\t on the\t death of  a beneficiary  to
\napply his share to the maintenance of his widow and his male
\nissue and  to accumulate  the surplus  to the account of the
\nsaid beneficiary  for distribution.  On\t the  contrary,\t the
\ntrustees would\thave been under an obligation to entrust the
\nincome falling\tto the\tshare of the deceased beneficiary to
\nthe members  of his Hindu undivided family and no discretion
\nwould have  been permissible  in regard\t to the\t disposal or
\notherwise of  any part thereof. Secondly, the document would
\nnot have  provided that\t if before  the time of division and
\ndistribution a\tbeneficiary died  leaving only\ta widow, the
\nwidow would  get a  half  of  the  share  belonging  to\t the
\ndeceased beneficiary while the other half would be liable to
\ndistribution among the remaining beneficiaries and the heirs
\nof other  deceased beneficiaries.  These two  conditions are
\nsufficient in  themselves to  lead to the conclusion that it
\nwas never  intended that  the properties  should pass to the
\nbeneficiaries to  be held by them for their respective Hindu
\nundivided families.  On the  plain terms of the trust deeds,
\nthe properties were intended to devolve on the beneficiaries
\nin their individual capacity.\n<\/p>\n
1028<\/span><\/p>\n
     It is  contended by  learned counsel  for the  assesses
\nthat the  settlors intended  under the\ttwo trust  deeds  to
\nprotect the  grandsons, and  the scheme\t incorporated in the
\ntrust deeds must be regarded as akin to a family settlement.
\nWe are\tunable to  agree. The  interest of the grandsons has
\nbeen sufficiently  protected by\t the terms and conditions of
\nthe trust  deeds, and in order to safeguard that interest it
\nis not\tnecessary  to  conclude\t that  the  properties\twere
\nintended to  go to  the beneficiaries as Kartas of the Hindu
\nundivided   families.\t The   grandsons   themselves\twere
\nbeneficiaries and  on the  division and\t distribution of the
\nproperties they\t would have  full power\t to deal  with\tthem
\naccording to  their will  and discretion. It is only where a
\nbeneficiary dies  before division  and distribution  of\t the
\nproperties without leaving a widow or sons that the trustees
\nare empowered  to intervene and direct, subject to providing
\nfor the\t maintenance, education and marriage of the deceased
\nbeneficiary’s daughters,  that the share of such beneficiary
\nbe divided  among the  remaining beneficiaries and the heirs
\nof deceased beneficiaries.\n<\/p>\n
     We are  of opinion that the High Court has erred in the
\nview taken  by it  of the  two\ttrust  deeds  and  that\t the
\nAppellate   Tribunal   was   right   in\t  its\tconclusions.
\nAccordingly, we\t answer the  question referred\tto the\tHigh
\nCourt in  each case  in the  affirmative, in  favour of\t the
\nRevenue and  against the  assessees. The appeals are allowed
\nwith costs.\n<\/p>\n
A.P.J.\t\t\t\t\t    Appeals allowed.\n1029<\/span>\n\n\n\n<\/pre>\n","protected":false},"excerpt":{"rendered":"
Supreme Court of India Commissioner Of Income-Tax, … vs Maharaja Bahadur Singh & Ors on 13 October, 1986 Equivalent citations: 1987 AIR 518, 1986 SCR (3)1020 Author: R Pathak Bench: Pathak, R.S. PETITIONER: COMMISSIONER OF INCOME-TAX, MADHYA PRADESH Vs. RESPONDENT: MAHARAJA BAHADUR SINGH & ORS. DATE OF JUDGMENT13\/10\/1986 BENCH: PATHAK, R.S. BENCH: PATHAK, R.S. MUKHARJI, […]<\/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-243761","post","type-post","status-publish","format-standard","hentry","category-supreme-court-of-india"],"yoast_head":"\nCommissioner Of Income-Tax, ... vs Maharaja Bahadur Singh & Ors on 13 October, 1986 - 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\/commissioner-of-income-tax-vs-maharaja-bahadur-singh-ors-on-13-october-1986\" \/>\n<meta property=\"og:locale\" content=\"en_US\" \/>\n<meta property=\"og:type\" content=\"article\" \/>\n<meta property=\"og:title\" content=\"Commissioner Of Income-Tax, ... vs Maharaja Bahadur Singh & Ors on 13 October, 1986 - 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