COMMISSIONER OF INCOME-TAX CENTRAL, CALCUTTA & ANR. vs AMALGAMATED DEVELOPMENT, LTD.

The Supreme Court held that under Section 10(2)(xv) of the Income-tax Act, 1922, the expenditure incurred by the respondent company for the development of plots previously sold by the firm is deductible, as it is necessary for the business operations. The Court ruled that the entire sale price of the plots, even if part was secured by mortgage, does not constitute constructive receipt of income. The appeal by the Income-tax Department was dismissed, affirming the High Court's decision in favor of the respondent company.