COMMISSIONER OF INCOME-TAX, MADRAS vs K. H. CHAMBERS, MADRAS

The Supreme Court interpreted Section 25(4) of the Indian Income-tax Act, 1922, clarifying that 'succession' involves a complete transfer of ownership where the transferor exits and the transferee assumes control, preserving the business's identity and continuity. The Court held that the High Court has jurisdiction under Section 66(1) to review findings on succession, affirming that the determination of whether facts meet the legal criteria for succession is a mixed question of law and fact. The appeal was allowed, confirming the applicability of Section 25(4) to the case at hand.