As per the case facts, a carriage contractor was assessed under a section of the Income Tax Act concerning "other valuable articles" for bitumen transport, a common road material. The ... reason for the appeal to the Supreme Court was to determine if bitumen should be classified as a "valuable article" under the relevant income tax provision. The question arose whether bitumen can be considered a 'valuable article' under Section 69A of the Income Tax Act, 1961. Finally, the Supreme Court ruled that bitumen is not a valuable article for the purpose of Section 69A, stating that the law was intended for precious items like bullion and jewellery, which can hide undeclared earnings, unlike common materials. The Court concluded that the assessee was not the owner of the bitumen for the purpose of this section.