S. G. MERCANTILE CORPN. (P) LTD. vs THE C.I.T., CALCUTTA

The Supreme Court held that the income of the appellant company from sub-letting stalls was assessable under Section 10 of the Income Tax Act, 1922, as it constituted business income. The Court clarified that Section 12 could only be invoked if Section 10 was inapplicable, which was not the case here. The ruling emphasized that the company's activities of leasing and developing property fell within the definition of 'business' under Section 2(4) of the Act, thus overturning the High Court's decision.