ISHWARLAL GIRDHARLAL PAREKH vs STATE OF MAHARASHTRA AND ORS.

The Supreme Court held that an assessment order under Section 420 IPC is considered 'property' in the hands of the assessee as it determines tax liability, thus satisfying the definition of 'valuable security'. The Court clarified that the communication of an assessment order constitutes 'delivery' for the purposes of cheating, and the deception occurs when the Income-tax Officer is induced to make a wrong assessment. The framing of charges under Section 420 IPC was upheld, affirming the lower courts' decisions.