COMMISSIONER OF INCOME-TAX, ANDHRA PRADESH vs H. E. H. MIR OSMAN ALI KHAN

The Supreme Court held that the privileges guaranteed by the merger agreement were personal to the Nizam of Hyderabad and did not exempt him from taxation under the Income-tax Act, 1922. The Court ruled that Hyderabad State never acquired international personality under International Law, thus the Nizam could not claim immunity from taxation. The Court clarified that the assessment of income tax is based solely on the provisions of the Income-tax Act, irrespective of any prior exemptions or international law claims, affirming the High Court's decision in part and reversing it in others.