VIBHUTI GLASS WORKS vs COMMISSIONER OF INCOME TAX, LUCKNOW

The Supreme Court held that under Section 28 of the Income Tax Act, 1961, the entire profits from the glass factory were assessable to the assessee, despite the State Government managing the factory. The Court clarified that the income accrued directly to the assessee and was merely applied to settle its debts, rejecting the argument that profits were diverted through an overriding title. The appeal was dismissed, affirming the High Court's ruling that the profits were not assessable in the hands of the State Government.