RAMESHWAR PRASAD BAGLA vs COMMISSIONER OF INCOME-TAX, U.P., LUCKNOW

The Supreme Court held that the High Court, in a reference under Section 66 of the Indian Income Tax Act, 1922, does not act as a court of appeal but exercises advisory jurisdiction. The Court ruled that interference with findings of fact is permissible only when there is no relevant evidence or the findings are based on conjecture. The Court concluded that the profits from the sale of shares constituted capital gains chargeable to income tax under Section 12(b) of the Act, thus reversing the High Court's decision.