PR. AL. M. M. ANNAMALAI CHETTIAR vs COMMISSIONER OF INCOME-TAX, MADRAS

The Supreme Court upheld the Income-tax Officer's method of computing profit and loss for properties purchased in Japanese currency and sold in Malayan currency during the assessment year 1951-52. The Court ruled that the Officer was justified in using the schedule from the Debtor and Creditor (Occupation Period) Ordinance, 1948, to ascertain the cost price in Malayan currency, despite the Ordinance's primary purpose being for scaling down payments during the occupation. The Court confirmed that profit or loss can only be determined when the conversion rate of the currencies is known, and the adopted method was appropriate for the assessment year in question.