Rm. Ar., Ar. Rm. Ar. RAMANATHAN CHETTIAR vs COMMISSIONER OF INCOME-TAX, MADRAS

The Supreme Court held that the interest paid to the assessee under the decree of the Supreme Court of Ceylon on the estate duty refund is taxable under the Indian Income-tax Act, specifically under Section 4(3)(vii). The Court clarified that such interest is not a capital receipt but rather income of a recurring nature, as it was calculated on a daily basis from the date of the trial court proceedings. The jurisdiction of the High Court under Section 66 was also affirmed, emphasizing that it can only decide questions referred to it or arising from the Tribunal's order.