COMMISSIONER OF INCOME-TAX, WEST BENGAL, CALCUTTA vs CALCUTTA HOSPITAL AND NURSINGHOME BENEFITS ASSOCIATION

The Supreme Court held that the balance of profits of a mutual insurance concern is taxable under Section 2(6C) of the Indian Income Tax Act, 1922, as it falls within the definition of 'income'. The Court distinguished the case from Ayrshire Employers Mutual Insurance Association Ltd. v. Commissioner of Inland Revenue, emphasizing that 'profits' in Rule 6 refers to the balance of profits disclosed in accounts, not just taxable profits. The Court affirmed that reserves for income tax, which were not considered expenditure, could not be taxed, aligning with the High Court's ruling.