KARNANI PROPERTIES LTD. vs COMMISSIONER OF INCOME TAX, WEST BENGAL

The Supreme Court held that the High Court's jurisdiction under Section 66 of the Income Tax Act, 1922 is limited to the facts stated in the Tribunal's statement of case, and it cannot question the Tribunal's findings unless vitiated by recognized legal reasons. The Court found that the assessee company had two distinct sources of income: rental income and income from services provided to tenants, thus overturning the High Court's conclusion that the income was taxable under Section 9. The Court upheld the Tribunal's decision that the income should be treated as business income under Section 10.