CHINTAMANI SARANNATH SAH DEO vs C.I.T. BIHAR & ORISSA

The Supreme Court held that the premium received for a mining lease is a capital receipt, while periodic payments for the lease are revenue receipts. The Court emphasized that the nature of the transaction is determined by the circumstances rather than nomenclature, placing the onus on the Income-tax authorities to prove that the premium constitutes income. The Court upheld the High Court's decision, stating that the terms of the 1944 lease did not support the claim that part of the premium was capitalized royalty, and the Revenue failed to discharge its burden of proof.