COMMISSIONER OF INCOME TAX vs SHIVAKAMI CO. PVT. LTD.

The Supreme Court held that the first proviso to Section 12B(1) of the Indian Income Tax Act, 1922 applies only when the consideration for the transfer of a capital asset is understated. The Court emphasized that the Revenue must provide evidence of a higher amount received for the sale to invoke this proviso. The findings of the fact-finding body are not subject to challenge unless the inferences drawn are not supported by legal evidence or are irrational. The High Court's ruling that the consideration was not understated was upheld, leading to the dismissal of the appeals.