COMMISSIONER OF INCOME TAX, vs VIKRAM COTTON MILLS LTD.

The Supreme Court held that the income derived by the assessee company from leasing its assets is assessable under the head 'profits and gains of business' as per Section 10 of the Income Tax Act, rather than as 'income from other sources' under Section 12. The Court emphasized that the classification of income depends on the intention behind the exploitation of the assets, which in this case indicated a temporary suspension of business for reconstruction. The High Court's ruling was upheld, dismissing the revenue's appeal.