M/S Mepco Industries Ltd.Madurai vs Commr.Of Income Tax & Anr

The Supreme Court held that the Commissioner of Income Tax can rectify its own order under Section 154 of the Income Tax Act, 1961, based on a subsequent judgment, specifically referencing the case of Sahney Steel and Press Works Limited. The Court established that the power tariff subsidy received by the appellant was a revenue receipt and not a capital receipt, thus liable to be taxed under Section 28 of the Act. The Court affirmed the decisions of the Madras High Court, which upheld the rectification order of the Commissioner of Income Tax.