| Case ID |
fa9e5423-18ec-4843-b488-e2cf29deaf83 |
| Body |
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| Case Number |
CIVIL APPEAL No. 1553 OF 1970 |
| Decision Date |
Nov 12, 1974 |
| Hearing Date |
|
| Decision |
The Supreme Court held that a single individual cannot constitute a Hindu undivided family (HUF) for tax purposes. The court emphasized that the concept of 'family' inherently requires a plurality of persons, thus confirming that the status of the appellant as an individual was appropriate. The court also noted that although the appellant had properties from a prior HUF, he was not liable to be taxed as an HUF since he was the sole member and had not introduced any new members. Therefore, the appeal was dismissed as it had no merit. |
| Summary |
In the landmark case of C. Krishna Prasad v. Commissioner of Income Tax, the Supreme Court of India addressed the intricate issue of whether a single individual could be assessed as a Hindu Undivided Family (HUF) under the Income-tax Act, 1961. The court's ruling was clear: plurality of persons is a fundamental attribute of a family, and thus, an individual alone does not constitute an HUF. This case revolved around the interpretation of Section 4 and Section 2(31) of the Income-tax Act, which define the taxable entities. The appellant, a bachelor, argued that he should be assessed as an HUF based on properties received from a partition of a joint family. However, the court rejected this claim, affirming that the legal distinction between an individual and an HUF must be maintained. The judgment highlights the significance of understanding familial structures in the context of tax law, reinforcing that tax assessments must reflect the actual status of individuals concerning familial relations. This clarification is vital for taxpayers, legal practitioners, and tax authorities to ensure accurate tax compliance and avoid misinterpretations of family status in tax assessments. The ruling also aligns with precedents established in prior cases, solidifying the legal framework governing HUF assessments. |
| Court |
Supreme Court of India
|
| Entities Involved |
Not available
|
| Judges |
H. R. Khanna,
A. C. Gupta
|
| Lawyers |
S.T. Desai,
Vineet Kumar,
R.N. Sachthey
|
| Petitioners |
C. Krishna Prasad
|
| Respondents |
Commissioner of Income Tax
|
| Citations |
1974 SLD 666,
(1974) 97 ITR 493
|
| Other Citations |
C. Krishna Prasad v. CIT [1970] 75 ITR 526 (Mys.),
Attorney-General of Ceylon v. Ar. Arunachalam Chettiar [1958] 34 ITR (ED) 42 (PC),
CIT v. Rm. Ar. Ar. Veerappa Chettiar [1970] 76 ITR 467 (SC),
Gowli Buddanna v. CIT [1966] 60 ITR 293 (SC),
Anant Bhikappa Patil v. Shankar Ramchandra Patil [1943] AIR 1943 PC 196
|
| Laws Involved |
Income-tax Act, 1961
|
| Sections |
4,
2(31)
|