M/S. DALMIA DADRI CEMENT CO. LTD. vs THE COMMISSIONER OF INCOME-TAX(and connected petition)

The Supreme Court held that Section 3 of Ordinance No. 1 of S. 2005 extinguished the appellant's right to tax concessions under the agreement dated April 1, 1938, and that the appellant could not rely on that agreement after August 20, 1948. The Court ruled that the Covenant dated May 5, 1948, is an act of State, and Article VI cannot be invoked by the appellant against the Rajpramukh of the new State. Consequently, the appellant's claim for income-tax concessions was denied, affirming the applicability of the Indian Income-tax Act post-April 13, 1950.