Legal Street registered trademark

Supreme Court of India

M/s Jindal Equipment Leasing Consultancy Services Ltd. v. Commissioner of Income Tax

Neutral citation
Reported as [2026] 1 S.C.R. 517
Bench J.B. Pardiwala and R. Mahadevan JJ.
Decided 9 January 2026

INSC stands for INDIAN SUPREME COURT. A neutral citation scheme assigned by the Court itself, so a judgment can be cited without depending on a commercial law reporter. INSC is the neutral citation scheme assigned by the Supreme Court, so a judgment can be cited without depending on a commercial law reporter.

What the Court ordered

In view of the foregoing discussions, we reiterate that Section 28 of the I.T. Act is of wide import and encompasses all profits and gains arising in the course of business, even when such profit is realised in kind.

Judgment, page 61

From the headnote

Issue for Consideration Issue arose as regards taxability of gains said to arise on amalgamation, where shares of the amalgamating company held by the assessees as stock-in-trade, stand substituted by shares of the amalgamated company; whether such substitution, in and of itself, constitutes a realisation giving rise to taxable business income u/s.28, Income Tax Act, 1961 and if so, the conditions under which such accrual or receipt can be said to arise in the commercial sense, or whether the incidence of taxation arises only upon the subsequent sale of the substituted shares; whether the

Authorities it was built on

Sign in free to read it

  • The full judgment, page by page, as published in the Supreme Court Reports
  • The ratio: what the Court held, verbatim, with the page it sits on
  • Every bench that relied on it, and every bench that argued against it
  • Search every reported judgment, by party, citation or question
  • Download the PDF, copy pinpoint citations ready for a filing
Sign in to read - for free

An email address, no password.