COMMISSIONER OF INCOME-TAX, PUNJAB JAMMU& KASHMIR, HIMACHA vs PUNJAB DISTILLING INDUSTRIES LTD.

The Supreme Court held that amounts described as 'security deposit' collected by a distiller for empty bottles were trading receipts assessable to income tax under Section 10 of the Indian Income-tax Act, 1922. The Court clarified that these amounts were integral to the sale transaction and not true security deposits, as there was no right to the return of bottles. The judgment reaffirmed the principles established in Punjab Distilling Industries Ltd. v. Commissioner of Income-tax, and the High Court's contrary view was deemed erroneous.