The case examined whether reassessment approval beyond three years was issued by the competent authority. The court held that approval by an unauthorized officer invalidates the proceedings and set aside the notice.
The case examined whether interest earned on temporarily parked funds is taxable. The court held that funds earmarked for asset acquisition are not surplus, and interest must be treated as capital receipt.
The Tribunal held that reassessment proceedings were invalid as approval was taken from the wrong authority beyond three years. It ruled that such non-compliance with Section 151(ii) vitiates jurisdiction and renders the notice void.
The Court examined whether successive review petitions were maintainable. It held that without new evidence or error apparent, a second review is impermissible and restored the original judgment.
The court examined whether interest on FDRs could be taxed as other income. It held that where funds are linked to a project, the interest retains its project nexus and is not separately taxable.
The court examined whether interest on share capital parked temporarily could be taxed. It held that where funds are directly linked to project setup, the interest is a capital receipt and not taxable as other income.
The Court examined whether review jurisdiction permits re-evaluation of evidence. It held that such reappreciation is impermissible and restored the original writ judgment.
The Court examined whether review powers were properly exercised. It held that the High Court exceeded its jurisdiction by re-evaluating evidence, restoring the original findings.
The Court examined whether tax authorities can issue a single order for multiple years. It held that composite orders are invalid and directed separate orders for each year.
The petitioner alleged denial of hearing and cross-examination. The Court ruled that no such violation was established at this stage and deferred such issues to appropriate proceedings.
