Section 56 — Income from Other Sources (Charging)

Case Laws & Commentary

INCOME-TAX ACT, 1961

CHAPTER IV-F — INCOME FROM OTHER SOURCES

SECTION 56 — INCOME FROM OTHER SOURCES

Case Laws, Section Commentary & FA 2026 Note

(For inclusion in the bharattax.co 1961 Treatise — companion to Treatise Vol IV-E, Income from Other Sources)

A. SECTION COMMENTARY

Section 56 is the residuary head of charge under Chapter IV of the Income-tax Act, 1961. Sub-section (1) charges to tax every kind of income of an assessee which is not chargeable under any of the four preceding heads (Salaries, Income from House Property, Profits and Gains of Business or Profession and Capital Gains) and which is not exempt under the Act. Sub-section (2), originally a short enumerative list of items deemed to fall under this head (dividends, winnings, employee contributions, interest on securities, hire of plant/machinery and composite letting), has expanded steadily since 2004 into the principal anti-abuse provision of the Act, comprehending — in chronological order of insertion — clauses (v), (vi), (vii) and (viia) on gifts, (viib) on excess share-premium, (viii) on interest on enhanced compensation, (ix) on forfeiture of advance for capital asset, (x) on omnibus receipt of money or property without (or for inadequate) consideration, (xi) on compensation on termination/modification of employment, (xii) on distributions by business trusts/InvITs and (xiii) on sums received under specified life-insurance policies.

The section therefore performs three distinct functions which must be kept analytically separate: (i) a residuary function under s. 56(1) — catching genuine income not falling elsewhere (Eastern Investments; D.P. Sandu Bros.); (ii) a deeming function in respect of specified items under s. 56(2)(i)-(id), (ii), (iii), (viii), (ix), (xii), (xiii) — converting receipts that might or might not be "income" in the ordinary sense into chargeable income; and (iii) an anti-avoidance function under s. 56(2)(v)-(vii), (viia), (viib), (x), (xi) — countering tax-base erosion through gift-stripping, share-premium loading and structured employment exits. Because heads of income are mutually exclusive (East India Housing & Land Development Trust; Nalinikant Ambalal Mody), s. 56 can be invoked only when no antecedent head applies. Once a receipt is found to be capital in nature, it falls outside s. 56 unless one of the deeming clauses positively brings it in (Saurashtra Cement; Padmaraje R. Kadambande).

For computation, the section is to be read with s. 57 (deductions), s. 58 (amounts not deductible), s. 59 (recovery of amounts earlier allowed), s. 145(1) (cash or mercantile method of accounting), s. 145B (year of taxability for interest on enhanced compensation), s. 2(22) (deemed dividend), s. 2(24)(ix) (winnings), the Wealth-Tax / Stamp-Duty valuation framework imported by clauses (vii)/(viia)/(x), Rule 11U/11UA (valuation rules), and — for share-premium under (viib) — Rule 11UA(2) and the safe-harbour notifications issued by CBDT for start-ups under s. 56(2)(viib) proviso. Treaty interaction (especially Articles 10-13 of model DTAAs on dividend, interest and other income, and Article 22 "Other Income") is significant for non-residents; s. 90(2) permits the assessee to choose the more beneficial of the Act or the treaty.

B. FINANCE ACT, 2026 — IMPACT ON SECTION 56

Verified against the bare text of the Finance Act, 2026 (Act No. 4 of 2026, assented 30 March 2026), Chapter III, Part A — "Income-tax under the Income-tax Act, 1961". Part A of the Finance Act, 2026 amends only sections 92CA, 148, 222, 245, 245MA, 254, 270A and 270AA of the 1961 Act. Section 56 is NOT textually amended by the Finance Act, 2026.

Note. — Section 40 of the Finance Act, 2026 (which omits sub-clause (i) of sub-section (11)(a) of "section 58") sits in Part B of Chapter III and amends section 58 of the Income-tax Act, 2025 (Act 30 of 2025); it has no operation on section 56 of the 1961 Act. The case law set out below therefore continues to govern section 56 of the 1961 Act for all assessment years up to AY 2026-27 (the last AY under the 1961 Act) without any FA 2026 disturbance.

C. IMPORTANT CASE LAW — SECTION 56

1. Nalinikant Ambalal Mody v. S.A.L. Narayan Row, CIT [1966] 61 ITR 428 (SC)

Facts. The assessee, an advocate, ceased practice on appointment to the Bench in November 1955. In the previous year relevant to AY 1956-57 he received outstanding professional fees of Rs. 47,000 in respect of work done before he stopped practice. He kept his books on cash basis.

Issue. Whether professional receipts in respect of a profession that had ceased in an earlier year could be assessed under section 10 (now section 28) of the 1922 Act, and if not, whether they could be assessed under the residuary head "Income from other sources".

Held. Held by the Supreme Court (per Shah, J.) that since the profession had been discontinued in an earlier year, no income could be computed for the relevant year under the head Profits and Gains of Business or Profession; and a receipt which is income from one of the specified heads cannot be charged to tax under the residuary head if that head fails for reasons other than the absence of income. Charge under section 6 of the 1922 Act (= s. 14 of the 1961 Act) is exhaustive of the heads.

Ratio. If the income properly falls under one of the antecedent heads of charge, it cannot be assessed under the residuary head merely because computation under that antecedent head fails. The residuary head is for income that does not specifically belong elsewhere — not a catch-all for amounts that escape an antecedent head on a technicality.

2. East India Housing and Land Development Trust Ltd. v. CIT [1961] 42 ITR 49 (SC)

Facts. A company whose objects included buying, developing and letting out lands and markets had constructed shops and stalls in a market and let them out. It returned the rental income as business income.

Issue. Whether income from letting out shops and stalls of a market built and owned by the assessee company was assessable as "profits and gains of business" or as "income from house property".

Held. Held that the income was assessable under the head Income from House Property and not as business income. The heads of income enumerated in section 6 of the 1922 Act (= s. 14 of the 1961 Act) are mutually exclusive; specific income falling under a specific head must be computed under that head and cannot be brought under another head merely because of the activity carried on.

Ratio. The foundational principle of mutual exclusivity of heads of income. Section 56 cannot be invoked where the receipt squarely answers the description of a specific head — that head exhausts the field even if it yields a lower tax outcome.

3. D.P. Sandu Bros. Chembur (P) Ltd. v. CIT [2005] 273 ITR 1 (SC)

Facts. The assessee company surrendered tenancy rights in a flat and received a sum of Rs. 35 lakh from the landlord. The Revenue sought to bring the receipt to charge under section 56 as a casual receipt; the assessee contended it was a capital receipt from transfer of a capital asset assessable under section 45.

Issue. Whether surrender of tenancy rights and the consideration received therefor is assessable as capital gains under section 45 read with section 55(2)(a) or as income from other sources under section 56.

Held. Held that tenancy right is a capital asset within section 2(14); its transfer attracts section 45; section 55(2)(a) [post-FA 1994] provides that cost of acquisition of tenancy rights is taken to be nil. Once the receipt falls within the scope of section 45, it cannot be assessed under section 56. Income falling within a specific head must be computed under that head; section 56 is residuary and yields to the specific head.

Ratio. Re-affirms East India Housing for the post-1961 Act. Where a receipt is properly classifiable under any of the four preceding heads, recourse to section 56 is impermissible; the residuary head operates only when none of the specific heads applies.

4. CIT v. Saurashtra Cement Ltd. [2010] 325 ITR 422 (SC)

Facts. The assessee placed an order with a supplier for plant. The supplier delayed delivery. As per the contract, the assessee received liquidated damages of about Rs. 8.50 lakh from the supplier.

Issue. Whether the amount received as liquidated damages from a supplier of plant for delay in supply is a revenue receipt assessable under section 28 / section 56 or a capital receipt going to reduce the cost of the capital asset.

Held. Held by the Supreme Court that the damages were directly and intimately linked with the procurement of a capital asset (cement plant); they were paid to compensate the assessee for the delay in commencing the source of income itself. The receipt was therefore on capital account and not taxable as income.

Ratio. A receipt arising out of a sterilisation of the source of income, or directly linked with the acquisition of a capital asset, is a capital receipt outside the scope of section 56(1). The character of the receipt is determined by the character of the payment that was lost (here, delayed acquisition of plant), not by the manner of its computation.

5. Padmaraje R. Kadambande v. CIT [1992] 195 ITR 877 (SC)

Facts. The assessee, a former jagirdar, received certain sums from the Government on extinguishment of his rights consequent on agrarian reform legislation.

Issue. Whether payments received as compensation for extinguishment of source of income (zamindari/jagir rights) were capital receipts or taxable as income from other sources.

Held. Held to be capital receipts. Compensation paid for sterilisation or extinction of the very source of income is not income; it represents the price paid for parting with a capital asset and is outside the charge under section 56.

Ratio. Compensation for loss of source — as distinct from compensation for loss of profits — is capital in character and not assessable under section 56(1). The test is whether the payment fills a hole in the profits (revenue) or a hole in the assets (capital).

6. Dr. K. George Thomas v. CIT [1985] 156 ITR 412 (SC)

Facts. The assessee, an evangelist, received donations from his followers, said to be for the propagation of his religious mission.

Issue. Whether voluntary donations received by an individual in the course of, and as a return for, his vocation are taxable as income within section 2(24) and section 56.

Held. Held that the donations had a direct and causal nexus with the vocation carried on by the assessee. The receipts were periodic, expected and bore the character of income; they were therefore assessable. The element of voluntariness on the part of the donor does not change the income-character on the donee.

Ratio. A receipt arising from the exercise of a vocation, even if voluntary on the part of the payer, is income; mere absence of legal compulsion to pay does not convert revenue receipts into capital. Causal nexus with an activity carried on is decisive.

7. CIT v. G.R. Karthikeyan [1993] 201 ITR 866 (SC)

Facts. The assessee won a prize in the All-India Highway Motor Rally — a rally requiring skill in driving along a prescribed route within a stipulated time. The Revenue sought to bring the prize to charge as "winnings from any race" within section 2(24)(ix) read with section 56(2)(ib).

Issue. Whether the prize money received in a motor rally involving skill (not chance) constituted "winnings from any race" within the inclusive definition in section 2(24)(ix) and was assessable under section 56(2)(ib).

Held. Held that the words "any race" in section 2(24)(ix) are wide enough to cover a motor rally; the legislative intent of clause (ix), inserted by FA 1972, is to enlarge the meaning of "income" to include all such receipts, whether of a games-of-chance character or otherwise. The prize is assessable under section 56(2)(ib).

Ratio. Section 2(24)(ix) and section 56(2)(ib) are deeming provisions designed to bring within charge receipts that may not be income in the strict commercial sense. "Any race" includes any organised competitive event held on a route, irrespective of whether the winning depends on chance or skill.

8. Sultan Bros. (P) Ltd. v. CIT [1964] 51 ITR 353 (SC)

Facts. The assessee company let out a building together with furniture, fixtures and other appurtenances on a single composite rent.

Issue. Whether the income from letting of the building inseparably with plant/machinery/furniture was to be assessed under the head Income from House Property, or under section 56(2)(iii) (composite letting) as Income from Other Sources.

Held. Held that whether the letting is one inseparable letting is a question of fact in each case. Where, on a true construction of the agreement, the letting of the building and the plant/furniture is inseparable, the rent falls under section 56(2)(iii) and not under sections 22-27.

Ratio. The "inseparable letting" test for section 56(2)(iii): if the parties intended a single composite letting of building plus plant/furniture such that one could not be enjoyed without the other, the entirety is taxable under section 56(2)(iii); if separable, the building portion goes under section 22 and the plant/furniture portion under section 56(2)(ii).

9. CIT v. Rajendra Prasad Moody [1978] 115 ITR 519 (SC)

Facts. The assessees borrowed money to invest in shares. In the relevant year no dividend was declared on the shares. They claimed deduction under section 57(iii) of the interest paid on the borrowed funds against their other dividend income.

Issue. Whether interest on monies borrowed to acquire shares is deductible under section 57(iii) against dividend income (section 56(2)(i)) even when no dividend is in fact received in the year.

Held. Held that section 57(iii) requires that the expenditure be incurred for the purpose of making or earning income, not that income should in fact have been made or earned. The deduction is allowable even if no dividend is received in the relevant year.

Ratio. Establishes the "purpose test" — not the "actual earning test" — for deductions against income chargeable under section 56. The case is cited universally for the proposition that nexus with the purpose of earning, not the fruition of income, governs deductibility under section 57(iii). [Cross-reference: detailed discussion under s. 57.]

10. Bhagwan Dass v. CIT [2006] 287 ITR 377 (Punjab & Haryana HC)

Facts. The assessee received a gift from his son-in-law. The Revenue sought to bring it to charge under the predecessor of section 56(2)(v) on the ground that son-in-law was not within the definition of "relative".

Issue. Whether "relative" in the Explanation to (the then) section 56(2)(v) was confined to lineal blood relations or extended to relations by marriage including son-in-law.

Held. Held that the definition of "relative" by reference to section 2(41) was to be read in the context of section 56(2)(v); a son-in-law was not specifically included in the enumerated relations and could not be implied. The gift was therefore taxable.

Ratio. Establishes the strict-enumeration principle for the definition of "relative" in section 56(2)(v)/(vi)/(vii)/(x): the list is closed and exhaustive; the courts cannot read into it relations not specifically enumerated. Reinforced legislatively by the expanded definition introduced from 1 April 2010 to include spouse-side relations.

11. Vineetkumar Raghavjibhai Bhalodia v. ITO [2011] 46 SOT 97 (Rajkot ITAT)

Facts. The assessee, an individual, received a sum from his Hindu Undivided Family (HUF) of which he was a coparcener. The Revenue brought it to tax under section 56(2)(v) as a gift from a non-relative on the footing that an HUF is not specifically a "relative".

Issue. Whether a gift received by an individual from his own HUF is exempt under the proviso to section 56(2)(v) on the ground that the HUF is a "relative" qua its member.

Held. Held that an HUF is a group of relatives; receipts by a member of the HUF from the HUF must be regarded as receipts from a "relative" within the meaning of the Explanation to section 56(2)(v). The receipt was therefore not taxable.

Ratio. Settled position for the "HUF as a relative" question for the donee-member. The legislative response — Explanation to s. 56(2) clarified by FA 2012 — supports the ITAT view that an HUF qualifies as a relative qua its member-donee.

12. PCIT v. Cinestaan Entertainment (P) Ltd. [2021] 433 ITR 82 (Delhi HC)

Facts. A start-up issued equity shares at a premium. It supported the issue price by a discounted cash-flow (DCF) valuation report of a Chartered Accountant. The AO rejected the projections on the ground that the actual results in subsequent years did not match the projections, substituted his own "NAV" valuation, and assessed the excess premium under section 56(2)(viib).

Issue. Whether the Assessing Officer, while making an addition under section 56(2)(viib), can reject a DCF valuation report furnished by the assessee under Rule 11UA(2)(b) merely by comparing the projected figures with the actual results, and substitute his own valuation.

Held. Held by the Delhi High Court (confirming the ITAT) that DCF is one of the methods prescribed in Rule 11UA(2). The choice of method is the assessee's. Projections in a DCF are necessarily forward-looking; they cannot be tested by hindsight on actuals. The AO has no jurisdiction to substitute his own valuation unless he records cogent reasons why the methodology and inputs adopted by the valuer are unreliable.

Ratio. Foundational authority on the "substitution" question under section 56(2)(viib): the assessee chooses the method (NAV or DCF) under Rule 11UA(2); the AO may scrutinise the inputs but cannot displace the methodology, and hindsight on actuals is not a permissible ground.

13. Vodafone M-Pesa Ltd. v. PCIT [2018] 92 taxmann.com 73 (Bombay HC)

Facts. The assessee had issued shares at a premium and supported the premium with a DCF valuation. The AO and the revisional authority rejected the DCF and substituted NAV without giving reasons. Section 56(2)(viib) addition was made.

Issue. Whether the AO can ignore the DCF valuation method opted for by the assessee under Rule 11UA(2) and impose his own valuation without recording reasons for rejection.

Held. The Bombay High Court held that the AO/revisional authority must give cogent reasons before rejecting the valuation method chosen by the assessee. The order substituting valuation without recorded reasons was set aside.

Ratio. Companion to Cinestaan: the AO's right to scrutinise inputs into a DCF is preserved, but rejection of the methodology itself requires recorded reasons. The case is widely cited in writ-jurisdiction challenges to s. 56(2)(viib) additions.

14. Sudhir Menon (HUF) v. ACIT [2014] 148 ITD 260 / 162 TTJ 425 (Mumbai ITAT)

Facts. The assessee HUF was allotted additional shares by a closely-held company in proportion to its existing shareholding (a proportionate rights / bonus issue). The Revenue sought to assess the difference between the FMV of the allotted shares and the issue price under section 56(2)(vii)(c).

Issue. Whether shares received by an existing shareholder under a proportionate rights/bonus issue at below FMV are "received without consideration or for inadequate consideration" within section 56(2)(vii)(c), so as to attract tax in the hands of the recipient shareholder.

Held. The Mumbai ITAT held that a proportionate rights/bonus allotment to all existing shareholders is not a "receipt" attracting section 56(2)(vii)(c) — the value of the shareholder's holding remains the same; what increases in number is offset by a corresponding fall in per-share value. There is no benefit moving from the company to a particular shareholder at the cost of others.

Ratio. Leading ITAT authority on the application of section 56(2)(vii)(c) [and by extension section 56(2)(x)(c)] to proportionate rights/bonus issues. The ratio is followed in numerous later decisions and is cited as the principal defence in proportionate-issue assessments.

15. CIT v. Ghanshyam (HUF) [2009] 315 ITR 1 (SC)

Facts. The assessee received enhanced compensation along with interest under section 28 of the Land Acquisition Act, 1894 in respect of compulsory acquisition of agricultural land.

Issue. Whether interest under section 28 of the Land Acquisition Act, 1894 awarded on enhanced compensation forms part of compensation (and so is taxable as capital gains, if at all), or is interest income taxable under section 56.

Held. The Supreme Court drew a distinction between interest under section 28 (a part of enhanced compensation) and interest under section 34 (interest on delayed payment). Section 28 interest was held to be in the nature of compensation, not interest, and therefore not assessable as interest under section 56.

Ratio. Pre-FA 2009 position. The Legislature responded with section 56(2)(viii) and section 145B(1) (and section 57(iv) granting a 50% deduction) — both inserted by FA 2009 w.e.f. AY 2010-11 — which now bring interest on compensation/enhanced compensation, including section 28 interest, expressly within the residuary head on receipt basis. Ghanshyam continues to be read for the conceptual distinction even after the legislative override.

16. CIT v. Govindbhai Mamaiya [2014] 367 ITR 498 (SC)

Facts. The assessees received interest on enhanced compensation for land compulsorily acquired. The interest pertained to multiple earlier years but was received in one financial year after the court order.

Issue. Whether interest received on enhanced compensation, post-insertion of sections 56(2)(viii), 57(iv) and 145B(1), is to be spread over the years to which it relates or is to be taxed in the year of receipt.

Held. Held that, under sections 145B(1) and 56(2)(viii), interest on enhanced compensation is taxable in the year in which it is received, regardless of the years to which it pertains; the assessee is entitled to a deduction of 50% under section 57(iv). The judicial principle of spreading over earlier years no longer applies post-FA 2009.

Ratio. Settles the year-of-taxability question for section 56(2)(viii) interest. The receipt-basis rule of section 145B(1) is an exception to the general accrual rule of section 145, designed specifically for interest on compensation/enhanced compensation.

17. Universal Radiators v. CIT [1993] 201 ITR 800 (SC)

Facts. The assessee received insurance compensation for damage caused to a steamer carrying its raw materials. The Revenue sought to assess the amount in excess of the cost of the lost goods as income.

Issue. Whether insurance receipts in respect of destruction/loss of trading stock are taxable as revenue receipts, and the head of charge.

Held. Held that the excess of insurance compensation over the cost of stock-in-trade represented a profit on a trading transaction and was taxable as business income; insurance moneys for capital assets, on the other hand, would be capital. The character of the destroyed asset (stock vs. fixed asset) determines whether the receipt is revenue or capital.

Ratio. Useful authority on the revenue/capital divide for insurance receipts. For section 56 purposes, where the destroyed asset is neither stock-in-trade nor business asset, the residuary head may apply only if there is a deeming clause; otherwise the receipt remains capital.

18. CIT v. Khoday Eswarsa & Sons [1972] 83 ITR 369 (SC)

Facts. The Revenue had brought to tax certain cash credits in the books of the assessee as income from undisclosed sources, finally placing them under the residuary head.

Issue. Whether the burden of proof in respect of cash credits/unexplained receipts sought to be brought under "Income from Other Sources" lies on the assessee or on the Revenue, and the standard of proof required.

Held. Held that once unexplained credits/receipts are shown to exist in the books of the assessee, the initial onus to explain their nature and source is on the assessee; on failure to discharge it, the Revenue is entitled to draw an adverse inference and treat the amounts as income, ordinarily under the residuary head.

Ratio. Cited universally on the evidentiary architecture of section 68 / unexplained credits read with section 56. The Khoday Eswarsa onus rule operates alongside (and is not displaced by) the deeming machinery of sections 68 to 69D, which charge such amounts independently and not necessarily through section 56.

19. Apeak Infotech (P) Ltd. v. ITO / cognate ITAT decisions on non-resident share-premium

Facts. The assessee, a closely-held company, had received share application money/share premium from non-resident investors; the AO made an addition under section 56(2)(viib).

Issue. Whether section 56(2)(viib), which charges excess share premium received "from any person being a resident", applies to issue of shares to non-residents (for the period prior to FA 2023 expansion).

Held. Held by various ITAT benches that section 56(2)(viib), as worded before FA 2023, was expressly restricted to consideration received from a "resident" person. Issue of shares to a non-resident was outside the ambit of section 56(2)(viib) for AYs prior to AY 2024-25.

Ratio. The textual restriction of section 56(2)(viib) to consideration from "residents" applies for AYs up to 2023-24. Note: FA 2023 omitted the word "being a resident" w.e.f. AY 2024-25, bringing non-resident-funded share premium within the charge subject to the start-up safe-harbour.

20. Bilahari Investment (P) Ltd. v. CIT [2008] 299 ITR 1 (SC)

Facts. The assessee was engaged in subscribing to chit funds; it offered chit dividend / loss on the basis of the completed-contract / project-completion method, deferring recognition of bid amounts and contributions until termination of each chit.

Issue. Whether income arising from subscription to chit funds is to be recognised on completion of the chit or on an annual basis, and the head of charge.

Held. Held that the completed-contract method consistently followed by the assessee was a recognised method under section 145; the Revenue could not insist on the percentage-completion method merely because it would yield earlier revenue. The character of the receipt (dividend on chit, loss on bidding) governs the head of charge.

Ratio. Useful on the s. 145 / s. 56 interface for recurring chit-fund income. The case is regularly cited for the proposition that a consistently followed and recognised method of accounting cannot be disturbed merely to advance taxation.

D. PRACTITIONER'S NOTE — RECURRENT ASSESSMENT POINTS UNDER SECTION 56

1. Heads of income are mutually exclusive (East India Housing; D.P. Sandu Bros.); always first eliminate the four specific heads before pleading or assessing under section 56(1). 2. Capital receipts (Saurashtra Cement; Padmaraje R. Kadambande) fall outside section 56 unless a specific deeming clause brings them in. 3. For section 56(2)(vii)/(viia)/(x) gift-type additions, verify (a) the donee's status (individual/HUF only for (vii)), (b) the date of receipt against the legislative timeline, (c) the donor's relationship against the closed list in the Explanation, (d) the valuation under Rule 11U/11UA. 4. For section 56(2)(viib) excess share-premium additions, the assessee's choice of valuation method (DCF vs NAV) under Rule 11UA(2) is sacrosanct unless the AO records cogent reasons (Cinestaan; Vodafone M-Pesa). Check the start-up safe-harbour notifications and the eligible-investor / DPIIT-recognition position separately. 5. For section 56(2)(viii) interest on enhanced compensation, the receipt-basis rule of section 145B(1) overrides accrual; the 50% deduction under section 57(iv) is automatic and need not be claimed in a particular form. 6. For section 56(2)(xi)/(xii)/(xiii) (employment-termination, business-trust distributions, life-insurance receipts), the source-side characterisation and the exclusion-clauses (section 10(10D) etc.) must be cross-checked before invoking section 56.

E. SOURCES & CITATIONS

Bare-Act source: Income-tax Act, 1961 as amended by the Finance Act, 2025 (project canonical PDF) + Finance Act, 2026 (Act No. 4 of 2026, 30 March 2026) — Chapter III, Part A verified for FA 2026 amendments to ss. 56-59. Case citations follow the Income Tax Reports (ITR) / ITAT (ITD / TTJ) / taxmann.com series as commonly cited in Indian tax practice; where multiple parallel citations exist, the primary ITR/SOT citation is given. Practitioners are advised to verify the latest position from the AIR / ITR online edition before relying on any case in a contested matter, as Supreme Court and High Court rulings post the date of this compilation may further refine or modify the principles stated.