M/S GUZDAR KAJORA COAL-MINES LTD. CALCUTTA vs THE COMMISSIONER OF INCOME TAX, CALCUTTA

The Supreme Court held that under Section 10(2)(vi) and Section 10(5) of the Income Tax Act, 1922, the original cost of an asset must be determined based on evidence available to the Income-tax authorities. The Court affirmed that the Income-tax Officer has the authority to reassess the valuation of assets beyond what is stated in the sale deed, especially if there are indications of collusion or misrepresentation. The appeal was dismissed, upholding the Tribunal's decision to include goodwill in the asset valuation.