COMMISSIONER OF INCOME-TAX, CALCUTTA vs SHAILA BEHARI LAL SINGHA

The Supreme Court held that the High Court erred in disposing of the reference under the Income-tax Act, 1922, without recording definitive answers to the questions posed. The Court emphasized that the High Court must provide clear answers regarding whether amounts received by the assessee constituted dividends under Section 2(6A) and whether they were taxable as income from 'other sources' under Section 12. The Court clarified that the determination of capital gains from salami and compensation for land acquisition must be made on a case-by-case basis, and the High Court's earlier judgment could not modify the finality of its answers.