COMMISSIONER OF INCOME TAX, KERALA vs K. SRINIVASAN

The Supreme Court interpreted Section 2(2) of the Finance Act, 1964, determining that 'income-tax' includes 'surcharge' and 'additional surcharge' as per legislative history and practice. The Court held that the Income-tax Officer's levy of surcharge was valid, overturning the High Court's ruling that excluded surcharge from the definition of income-tax. The judgment clarified that income-tax and super-tax can be charged at multiple rates, including basic charge, surcharge, special surcharge, and additional surcharge, in accordance with Article 271 of the Constitution.