M/S ORIENT TRADING COMPANY LTD. vs COMMISSIONER OF INCOME TAXCALCUTTA

The Supreme Court addressed the appeal concerning the assessment year 1963-64, where the Income Tax Appellate Tribunal had ruled that the exchange of shares between two companies constituted a realization of security resulting in profit. The Court upheld the Tribunal's decision, affirming that the market value of the shares received was significantly higher than the cost price, thus leading to a taxable profit of Rs. 4,06,000 under the Income Tax Act. The Court concluded that the High Court's ruling against the assessee was justified, confirming the tax liability.