The court held that challenges to deletion of Section 68 additions were factual in nature and raised no substantial question of law, leading to dismissal of the Revenue’s appeal.
SC dismissed SLP due to huge delay with costs. HC had quashed reassessment since it was issued despite stay on further proceedings.
The SC held that pending settlement proceedings do not bar restoration of income tax appeals. ITAT was justified in condoning delay and reviving appeals, subject to keeping them in abeyance.
The SC refused to interfere with the High Court’s ruling that reassessment notices issued on incorrect facts and without supporting material were invalid. The key takeaway is that mechanical reopening cannot survive judicial scrutiny.
The Supreme Court dismissed the Revenue’s appeal solely on account of unexplained delay, leaving the High Court’s decision undisturbed and reinforcing procedural discipline in tax litigation.
The Supreme Court upheld the centralisation of assessments under Section 127, holding that transfer for coordinated investigation following a search was justified. The ruling confirms that disclosed reasons and factual linkage are sufficient to sustain jurisdictional transfer.
The Court admitted the Revenue’s appeal against a tribunal ruling that set aside excise demands as revenue neutral. The key takeaway is that the legal question on valuation under Rules 8 and 9 remains open for final determination.
The Supreme Court held that purchasers who acquire property during pending litigation are bound by the decree and cannot obstruct execution of possession. Transfers made pendente lite remain subservient to the final decree and do not create independent rights against the decree holder.
The Supreme Court dismissed the Revenue’s appeal due to unexplained delay. This left intact the High Court ruling quashing reassessment based on a rejected share valuation.
The question was whether execution proceedings could extend to directors despite no findings against them. The Court ruled that directors cannot be bound in execution without pleadings, adjudication, and findings in the original proceedings.
