Reassessment quashed and left unchallenged, the merits of interest income taxability became infructuous

Once the reassessment was quashed by the first appellate authority and that finding was not challenged by the Revenue, the appeal on the merits of the taxability of interest income became infructuous. The tribunal held that no useful purpose would be served by examining the applicable tax rate when the foundational reassessment itself no longer survived for adjudication, and the Revenue's appeal was dismissed on that basis.

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Issues: Whether the Revenue's appeal on the merits of the taxability of interest income survived after the reopening of assessment had been quashed and the reopening was not challenged.

Analysis: The reassessment had already been annulled by the first appellate authority, and that finding was not assailed by the Revenue. In that situation, adjudication on the merits of the tax rate applicable to the interest income would serve no practical purpose, since the foundational reassessment itself no longer survived for examination.

Conclusion: The Revenue's appeal was dismissed as the merits became purposeless once the reopening was held invalid and remained unchallenged.

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