Issues: Whether duty amounts deposited under protest were to be treated as duty deposits governed by Section 11B of the Central Excise Act, 1944, and whether interest on refund was payable from the date of deposit or only after expiry of three months from the refund application under Section 11BB of the Central Excise Act, 1944.

Analysis: The Tribunal held that the amounts paid by the appellant, though under protest, retained the character of central excise duty and therefore the refund claim was governed by Section 11B of the Central Excise Act, 1944. Relying on the settled principle that the statute is a self-contained code for refund and that Section 72 of the Indian Contract Act, 1872 cannot be used to bypass the statutory refund mechanism, the Tribunal rejected the claim for interest from the date of deposit. The Tribunal further held that interest on delayed refund is regulated exclusively by Section 11BB of the Central Excise Act, 1944, which becomes applicable only when refund is not made within three months from the date of receipt of the refund application.

Conclusion: The claim for interest from the date of deposit was rejected, but the appellant was held entitled to interest at 6% per annum under Section 11BB of the Central Excise Act, 1944 from the date after expiry of three months from the refund application.

Final Conclusion: The appeal succeeded only to the limited extent of securing statutory interest for delayed refund under Section 11BB, while the wider claim for interest from the original date of deposit was denied.

Ratio Decidendi: In refund matters under the Central Excise Act, 1944, duty paid under protest remains governed by Section 11B, and interest for delayed refund is payable only under Section 11BB from the expiry of three months after receipt of the refund application, not from the date of deposit.

Issues: Whether a show-cause notice and consequent adjudication under the CGST Act issued against an amalgamating company after it had ceased to exist on merger are sustainable in law.

Analysis: The company against which the notice was issued had already merged with the petitioner pursuant to a court-approved scheme of amalgamation, and the Department had been informed of the merger. The liability sought to be enforced arose from notices issued in the name of the dissolved entity. Section 87 of the Central Goods and Services Tax Act, 2017 was held not to authorise initiation of proceedings against a non-existent company after merger; it deals only with the treatment of companies during the relevant intervening period and the cancellation of registrations. Following the principle that proceedings initiated against a defunct amalgamating company are void when the authority has knowledge of the amalgamation, the adjudication founded on such notice was held to be without jurisdiction.

Conclusion: The notice issued to the non-existent amalgamating company and the order passed thereon were void ab initio and unsustainable in law.

Issues: (i) Whether the delay in filing the appeal before the first appellate authority deserved condonation; (ii) whether compensation received under BSNL VRS-2019 was exempt under Section 10(10B) of the Income-tax Act, 1961 and the consequential refund could be directed.

Issue (i): Whether the delay in filing the appeal before the first appellate authority deserved condonation.

Analysis: The appeal involved a long delay, but the explanation was that the assessee had acted under bona fide ignorance of the exemption available on the VRS compensation and had no legal knowledge at the relevant time. The Tribunal noted that similar delays in identical BSNL VRS matters had already been condoned, that a liberal approach in limitation matters was supported by settled principles, and that the departmental circular required officers not to take advantage of an assessee's ignorance of rights.

Conclusion: The delay was liable to be condoned and the assessee's challenge could not be rejected on limitation alone.

Issue (ii): Whether compensation received under BSNL VRS-2019 was exempt under Section 10(10B) of the Income-tax Act, 1961 and the consequential refund could be directed.

Analysis: The Tribunal followed earlier coordinate bench decisions on identical BSNL VRS-2019 receipts and held that the compensation was covered by the exemption under Section 10(10B). It also held that an appellate authority could entertain a legitimate claim for relief even if the claim was not made in the return, and that the reliance on Goetze (India) Ltd. was misplaced in appellate proceedings. The AO was accordingly required to compute income on that basis and grant refund, if any, as per law.

Conclusion: The compensation received under BSNL VRS-2019 was exempt under Section 10(10B), and consequential relief by way of recomputation and refund was directed.

Final Conclusion: The appeals were allowed to the extent that the assessee obtained relief on limitation and on the merits of exemption, resulting in a partial allowance of both appeals.

Issues: Whether reassessment proceedings and the consequent assessment were vitiated for want of approval from the prescribed specified authority under the reassessment scheme applicable to the relevant assessment year.

Analysis: For assessment year 2017-18, the record showed approval under section 151 of the Income-tax Act, 1961 from the Principal Commissioner of Income Tax. On the admitted facts, the approval required for the reassessment action was that of the prescribed authority for the relevant assessment year. The defect went to the root of the reassessment jurisdiction, and the reassessment could not be sustained.

Conclusion: The reassessment proceedings and the consequent assessment were quashed, and the assessee succeeded.

Issues: (i) whether penalty under section 271DA could be sustained in the absence of discernible satisfaction in the assessment order regarding contravention of section 269ST; (ii) whether penalty could be upheld on the basis of seized tally data, statements and an estimated assessment without independent person-wise or transaction-wise proof of receipt in prohibited cash mode.

Issue (i): whether penalty under section 271DA could be sustained in the absence of discernible satisfaction in the assessment order regarding contravention of section 269ST.

Analysis: Penalty under section 271DA is attracted only when the Assessing Officer records a clear and conscious satisfaction, in the assessment order itself, that the statutory ingredients of section 269ST are met. Such satisfaction is a jurisdictional prerequisite and cannot be supplied later through the penalty notice, penalty order or appellate proceedings. A mere reference to penalty proceedings, without a clear finding on the nature of receipt, mode of payment, identity of payer, threshold limit and the statutory breach, is insufficient to confer jurisdiction.

Conclusion: The absence of recorded satisfaction in the assessment order rendered the initiation of penalty proceedings invalid, and the penalty could not be sustained.

Issue (ii): whether penalty could be upheld on the basis of seized tally data, statements and an estimated assessment without independent person-wise or transaction-wise proof of receipt in prohibited cash mode.

Analysis: The seized material and statements showed unaccounted cash receipts and were used for estimating income, but they did not conclusively establish, for penalty purposes, that any identifiable person paid two lakh rupees or more in cash in a day, in a single transaction, or in relation to one event or occasion. Once the books were rejected and income was determined on estimation, the same uncorroborated entries could not be selectively treated as conclusive proof of a statutory breach. In penalty proceedings, the Revenue had to prove the exact violation with cogent and independent material, and an admission of additional income did not amount to admission of contravention of section 269ST.

Conclusion: The penalty failed on merits as well, because the alleged contravention of section 269ST was not proved by independent and conclusive evidence.

Final Conclusion: The impugned penalty was held unsustainable in law for want of jurisdictional satisfaction and want of proof of the statutory violation, so the assessee succeeded in both appeals.

Ratio Decidendi: Penalty under section 271DA requires a clear recorded satisfaction in the assessment order and conclusive, independent proof of person-wise or transaction-wise cash receipt in breach of section 269ST; estimated additions, rejected books and uncorroborated admissions are insufficient to sustain the penalty.

Issues: (i) Whether the rectification order was vitiated for want of notice and opportunity of hearing under section 154(3) of the Income-tax Act, 1961. (ii) Whether the appellate authority could use rectification powers under section 154 of the Income-tax Act, 1961 to review, recall or reverse its earlier appellate order.

Issue (i): Whether the rectification order was vitiated for want of notice and opportunity of hearing under section 154(3) of the Income-tax Act, 1961.

Analysis: The impugned order was passed without issuing notice to the assessee before making the amendment. The statutory requirement of affording an opportunity of being heard before an adverse rectification was treated as mandatory, and non-compliance rendered the order ex parte.

Conclusion: The rectification order was invalid on account of breach of the mandatory hearing requirement and was liable to be set aside.

Issue (ii): Whether the appellate authority could use rectification powers under section 154 of the Income-tax Act, 1961 to review, recall or reverse its earlier appellate order.

Analysis: Rectification under section 154 is confined to correcting a mistake apparent from the record. It cannot be used as a substitute for review or as a means to revisit a concluded appellate decision on a debatable issue. The earlier appellate order in favour of the assessee could not be reopened through rectification.

Conclusion: The rectification exceeded the permissible scope of section 154 and was unsustainable.

Final Conclusion: The assessee succeeded on the jurisdictional and procedural challenge, and the adverse rectification order was set aside.

Ratio Decidendi: Rectification under section 154 cannot be used to review a concluded order, and any amendment made without the mandatory opportunity of hearing is legally unsustainable.

Issues: Whether reassessment under section 147 of the Income-tax Act, 1961 was valid when initiated beyond four years from the end of the assessment year despite no recorded failure by the assessee to fully and truly disclose material facts, and whether the reopening was based only on a change of opinion.

Analysis: The reasons recorded for reopening did not allege any failure on the part of the assessee to disclose fully and truly all material facts necessary for assessment. The material relating to recruitment and training expenses had already been disclosed in the audited financial statements and in the return of income filed under section 139(1) of the Income-tax Act, 1961, and had been available during the original assessment under section 143(3) of the Income-tax Act, 1961. No new tangible material or external information was identified in the reasons to believe, and the reopening was founded on re-examination of the same material already on record.

Conclusion: The reassessment was without jurisdiction, being based on a mere change of opinion and lacking the mandatory condition for reopening beyond four years.

Issues: (i) Whether the delay in filing the appeal before the Commissioner (Appeals) against the intimation under section 143(1) of the Income-tax Act, 1961 could be condoned and the assessee's fresh claim for exemption under section 10(10B) in respect of BSNL VRS-2019 compensation could be entertained; (ii) whether the compensation received under BSNL VRS-2019 was exempt under section 10(10B) of the Income-tax Act, 1961; (iii) whether the enhanced exemption relating to leave encashment under section 10(10AA) based on Notification No. 31/2023 applied to the assessment years in question.

Issue (i): Whether the delay in filing the appeal before the Commissioner (Appeals) against the intimation under section 143(1) of the Income-tax Act, 1961 could be condoned and the assessee's fresh claim for exemption under section 10(10B) in respect of BSNL VRS-2019 compensation could be entertained.

Analysis: The appeal was filed after delay on account of the assessee's bona fide ignorance of the exemption claim and the fact that tax had already been deducted at source from the compensation. The reasoning was supported by the principle that substantial justice should prevail over technicalities, by the CBDT's instruction not to take advantage of an assessee's ignorance of rights, and by the settled position that appellate authorities are competent to entertain a new legal claim even if it was not made in the return.

Conclusion: The delay was condoned and the fresh claim was held entertainable in appellate proceedings, in favour of the assessee.

Issue (ii): Whether the compensation received under BSNL VRS-2019 was exempt under section 10(10B) of the Income-tax Act, 1961.

Analysis: The matter was treated as covered by earlier Tribunal decisions involving identically placed BSNL employees, where similar compensation under BSNL VRS-2019 was held to be exempt. No distinguishing factual or legal feature was shown by the Revenue, and the earlier view was followed.

Conclusion: The compensation received under BSNL VRS-2019 was held exempt under section 10(10B), and the Assessing Officer was directed to recompute income and grant refund, if due, in favour of the assessee.

Issue (iii): Whether the enhanced exemption relating to leave encashment under section 10(10AA) based on Notification No. 31/2023 applied to the assessment years in question.

Analysis: The notification enhancing the exemption limit was stated to apply from 01.04.2023. Since the appeals related to assessment years 2020-21 and 2021-22, the enhanced limit did not apply to those years.

Conclusion: The additional ground relating to leave encashment exemption was rejected and was against the assessee.

Final Conclusion: The appeals were allowed to the extent of exemption for BSNL VRS-2019 compensation under section 10(10B), while the claim for enhanced leave-encashment exemption under section 10(10AA) was rejected, resulting in a partly allowed disposal.

Ratio Decidendi: An appellate authority may entertain a bona fide fresh legal claim and condone delay where substantial justice so requires, and a notification enhancing a tax exemption operates only from its specified effective date unless the statute or notification clearly provides otherwise.

Issues: Whether the addition made on account of cash deposits in the assessee's bank account could be sustained, or whether the matter should be restored to the Assessing Officer for fresh adjudication after examining ownership of the deposits, the role of the assessee, and the supporting material.

Analysis: The assessee's explanation was that the bank account had been used by third parties and that the deposits were not wholly his own funds. The record showed that no bank statement or particulars of the actual beneficiaries were furnished during assessment or appellate proceedings. At the same time, the available material and the surrounding circumstances, including the pattern of deposits and withdrawals and comparable tribunal decisions in similar matters, indicated that a blanket addition of the entire cash deposits would not be justified without proper inquiry. The appropriate course was therefore to set aside the addition and require the Assessing Officer to examine the issue afresh, confront the assessee with the deposit details, permit production of third-party particulars to the extent available, and decide the matter in accordance with law, including the assessee's plea for peak credit if pressed.

Conclusion: The addition was set aside and the matter was remanded to the Assessing Officer for de novo consideration. The assessee succeeded only partly, and the issue was restored for fresh adjudication with an opportunity of hearing.

Final Conclusion: Both appeals were partly allowed, with the impugned additions vacated for the time being and the assessment issues sent back for fresh decision on merits.

Ratio Decidendi: Where cash deposits in a bank account are alleged to represent unexplained income but the surrounding facts indicate possible third-party routing of funds, the entire deposits should not be sustained without proper inquiry; the matter may be remanded for fresh adjudication after affording the assessee an effective opportunity and examining the source and ownership of the deposits.

Issues: Whether the assessee-employer could be treated as an assessee in default under section 201(1) of the Income-tax Act, 1961, with consequential interest under section 201(1A), for not deducting tax at source on leave fare concession paid to employees whose travel included a foreign leg.

Analysis: The exemption under section 10(5) read with Rule 2B applies to travel from one place in India to another place in India by the shortest route, and the Supreme Court has settled that LTC/LFC does not extend to journeys involving a foreign leg. On the facts, no binding interim judicial order protecting the assessee from deduction was shown to govern the present assessee during the relevant period. In the absence of such protection, the statutory duty under section 192 remained operative, and failure to deduct tax attracted the deeming consequence under section 201(1), with interest under section 201(1A) following as a consequence.

Conclusion: The assessee was rightly held to be an assessee in default and the consequential interest was sustainable.

Final Conclusion: The appeal failed and the demand arising from non-deduction of tax on the impugned LFC payments was upheld.

Ratio Decidendi: Leave travel concession exemption is confined to travel within India by the shortest route, and where no binding judicial restraint excuses non-deduction, an employer who fails to deduct tax on taxable LFC payments is liable to be treated as an assessee in default under section 201.

Issues: Whether the amount surrendered during survey for assessment year 2017-18 could be subjected to tax at the enhanced rate under section 115BBE, or only at the rate applicable prior to the amendment.

Analysis: The surrendered sum was disclosed as professional receipts in relation to assessment year 2017-18. The Tribunal followed the view that the enhanced rate of tax under section 115BBE applies prospectively from assessment year 2018-19 and not to earlier years. On that basis, the higher rate invoked by the Revenue could not be applied to the year in question.

Conclusion: The enhanced tax rate under section 115BBE was held inapplicable to assessment year 2017-18, and the amount was directed to be taxed only at the normal rate; the issue was decided in favour of the assessee.

Ratio Decidendi: The enhanced rate of tax under section 115BBE operates prospectively and cannot be applied to assessment years prior to its effective date.

Issues: Whether the supervision charges for the appellant's special bonded warehouse were recoverable on Cost Recovery Charges basis or only on Merchant Over Time basis under the applicable warehousing regime and Board circular.

Analysis: Regulation 3(e) of the Special Warehouse Licensing Regulations, 2016 and paragraph 11 of Circular No. 32/2016-Cus dated 13.07.2016 require the licensing authority to determine the mode of recovery having regard to the frequency, duration and nature of the warehouse operations. Cost Recovery Charges apply where the customs officer's deployment is for the whole day, better part of the day, or comparable continuous supervision. On the record, there was no corroborative evidence that the customs officers were utilised for the entire day or for the better part thereof; the material indicated only limited-hour supervision. The appellant's own working out of charges on Merchant Over Time basis matched the actual usage pattern, and the demand based on Cost Recovery Charges could not be sustained.

Conclusion: The demand for Cost Recovery Charges was unsustainable, and the appellant was liable only for Merchant Over Time charges.

Final Conclusion: The impugned demand was set aside and the appellant obtained complete relief against the CRC-based recovery.

Ratio Decidendi: Where the customs supervision of a special warehouse is limited to part-day or other restricted use, and there is no evidence of full-day or better-part-of-day deployment, recovery must be made on Merchant Over Time basis and not on Cost Recovery Charges basis.

Issues: (i) whether the subsequent committee report dated 31.03.2021 furnished a ground to quash the criminal proceedings and PMLA complaint; (ii) whether the proceedings against the women accused could be quashed for want of incriminating material; (iii) whether delay in registration of the criminal case, alleged mala fides, and the plea that witness statements were merely stereotyped versions justified quashing; and (iv) whether the PMLA prosecution could be terminated on the basis that the predicate offences were disputed or not finally established.

Issue (i): whether the subsequent committee report dated 31.03.2021 furnished a ground to quash the criminal proceedings and PMLA complaint;

Analysis: The report was prepared for the limited purpose of assessing damages in recovery proceedings and did not determine criminal liability. The report was disputed, not accepted by the Government, and its evidentiary value, correctness, and admissibility were matters for trial. The existence or non-existence of civil recovery proceedings, or the acceptance of any committee report, would not by itself extinguish the criminal prosecution arising from the alleged illegal quarrying and laundering of proceeds.

Conclusion: The report dated 31.03.2021 did not justify quashing of the proceedings.

Issue (ii): whether the proceedings against the women accused could be quashed for want of incriminating material;

Analysis: The materials on record prima facie disclosed that the women accused were partners in the quarrying concern during the relevant period and were connected with the alleged illegal mining operations. Their later retirement from the firm did not erase possible liability for acts committed during the period of active association. The question of their exact role and participation required appreciation of evidence at trial.

Conclusion: The proceedings against the women accused were not liable to be quashed on that ground.

Issue (iii): whether delay in registration of the criminal case, alleged mala fides, and the plea that witness statements were merely stereotyped versions justified quashing;

Analysis: The allegations related to continuing and large-scale economic offences involving illegal quarrying, damage to public property, and alleged laundering of proceeds. In such a setting, delay in registration was not by itself fatal. Allegations of mala fides and the contention based on similarity of statements under Section 161 CrPC raised disputed factual questions and could not be decided in proceedings under Section 482 CrPC. The Court was not required to conduct a mini trial at the quash stage.

Conclusion: These grounds did not warrant interference.

Issue (iv): whether the PMLA prosecution could be terminated on the basis that the predicate offences were disputed or not finally established;

Analysis: The offence under the Prevention of Money Laundering Act, 2002 is distinct and independent. Once the complaint and accompanying materials disclosed prima facie proceeds of crime and laundering activity, the Court could not quash the prosecution merely because the accused disputed the predicate offences. The burden and evidentiary issues under the Act were matters for trial, and the existence of multiple surviving scheduled offences meant that the substratum of the PMLA case remained intact.

Conclusion: The PMLA proceedings were maintainable and not liable to be quashed.

Final Conclusion: The Court declined to exercise inherent jurisdiction to interfere with the criminal revisions and quash petitions, holding that the materials disclosed a prima facie case fit for trial and that all disputed factual and evidentiary issues must be resolved by the trial court.

Ratio Decidendi: Inherent jurisdiction under Section 482 CrPC cannot be used to quash criminal proceedings where the allegations disclose a prima facie case, the issues turn on disputed facts and evidence, and the PMLA prosecution is founded on surviving scheduled offences and alleged proceeds of crime.

Issues: Whether the dismissal of the first appeal for non-filing of a condonation of delay application was sustainable when the Order-in-Original itself stated an incorrect limitation period.

Analysis: Section 85 of the Finance Act, 1994 prescribes a two-month period for filing an appeal, with a further condonable period of one month on sufficient cause being shown. The Order-in-Original contained a positive misstatement that the appeal lay within three months, which could legitimately induce the appellant to believe that the appeal was within time and that no condonation application was required. A party should not suffer for a mistake made in the authority's own order, and the Commissioner (Appeals) could not dismiss the appeal mechanically without considering the circumstances that caused the procedural lapse.

Conclusion: The dismissal of the first appeal was unsustainable. The order-in-appeal was set aside and the matter was remanded to the Commissioner (Appeals) to consider the delay condonation application and decide the appeal on merits.

Issues: Whether a consolidated satisfaction note under Section 153C of the Income-tax Act, 1961, based on a regular ledger account, validly conferred jurisdiction for the relevant assessment year.

Analysis: A satisfaction note under Section 153C must be recorded separately for each assessment year. The material described as incriminating consisted merely of regular books of account in the form of ledger entries, without any explanation of their incriminating character. The consolidated satisfaction note, prepared for multiple assessment years without year-specific satisfaction, did not meet the jurisdictional requirement.

Conclusion: The consolidated satisfaction note did not validly confer jurisdiction under Section 153C of the Income-tax Act, 1961, and the assumption of jurisdiction was invalid.

Issues: Whether a reassessment notice signed on 31.03.2021 but issued and dispatched on 01.04.2021 was barred by limitation, and whether the consequential reassessment order could survive.

Analysis: The issue of a notice issued after midnight on 31.03.2021 had already been decided by the Court in an earlier batch of matters, and that decision had attained finality following dismissal of the challenges before the Supreme Court. The notice in question, though signed on 31.03.2021, was issued and dispatched only on 01.04.2021, beyond the prescribed limitation period. The consequential reassessment order rested upon that invalid notice.

Conclusion: The reassessment notice was time-barred and invalid; consequently, the reassessment order was also invalid. The decision is in favour of the assessee.

Issues: (i) Whether commercial collection of weekly-market fees by an auction lessee qualifies as a municipal function entitled to GST exemption; (ii) Whether COVID-period lease waiver and refund of lease amounts and security deposit can be claimed while GST and income-tax dues remain unpaid.

Issue (i): Whether commercial collection of weekly-market fees by an auction lessee qualifies as a municipal function entitled to GST exemption.

Analysis: The exemption concerning municipal functions under Article 243W and the relevant circular applies to services rendered by local authorities. An auction lessee collecting market fees exercises a commercially acquired contractual right under tender conditions and is not a local authority discharging a municipal function. The tender conditions also place liability for Central and State taxes upon the contractor.

Conclusion: The commercial market-fee collection by the lessee is not entitled to the claimed GST exemption; the issue is decided against the assessee.

Issue (ii): Whether COVID-period lease waiver and refund of lease amounts and security deposit can be claimed while GST and income-tax dues remain unpaid.

Analysis: The COVID-related Government Orders do not confer an unconditional entitlement to waiver or refund upon a lessee with outstanding statutory liabilities. The tender conditions permit adjustment of losses or expenditure from amounts payable to the licensee, and the outstanding GST and income-tax dues had not been discharged.

Conclusion: Waiver of lease amounts and refund of the security deposit cannot be granted until the outstanding statutory dues are cleared; the issue is decided against the assessee.

Final Conclusion: An auction lessee commercially collecting market fees must discharge applicable statutory liabilities before claiming COVID-related lease waiver or return of amounts payable under the tender.

Issues: (i) Whether a claimant could seek partition on a plea that the original purchase was benami without challenging the settlement deed under which the testatrix derived title?; (ii) Whether the registered Will was duly executed and attested despite the alleged suspicious circumstances?

Issue (i): Whether a claimant could seek partition on a plea that the original purchase was benami without challenging the settlement deed under which the testatrix derived title?

Analysis: The testatrix derived title under the settlement deed. The settlement deed and the title flowing from it had remained unchallenged since its execution, and no relief to set it aside was sought in the partition suit. The testatrix was therefore the absolute owner and competent to make a testamentary disposition of the property.

Conclusion: The claim for succession and partition fails; the finding is against the appellant.

Issue (ii): Whether the registered Will was duly executed and attested despite the alleged suspicious circumstances?

Analysis: The propounder and one attesting witness were examined, the other attesting witness having died. The evidence established execution and attestation in compliance with Section 63 of the Indian Succession Act, 1925 and Section 68 of the Indian Evidence Act, 1872. The alleged circumstances concerning the testatrix's age, health, residence registration, and the executor were unsupported by acceptable evidence. Registration at the testatrix's residence did not itself create suspicion, and the testamentary disposition was conscious and included the appellant as a beneficiary.

Conclusion: The Will is validly proved, and the grant of probate is sustained; the finding is against the appellant.

Final Conclusion: The unchallenged settlement vested absolute title in the testatrix, and her valid testamentary disposition governs the property, excluding a claim for partition contrary to the Will.

Ratio Decidendi: A registered Will is validly established where its execution and attestation satisfy statutory requirements and the alleged suspicious circumstances remain unproved.

Issues: Whether the Tribunal's order could be faulted by relying on the subsequent amendment to the proviso to Section 147A of the Income-tax Act, 1961.

Analysis: The amendment invoked by Revenue was introduced after the Tribunal had decided the matter. At the time of that decision, the applicable legal position was governed by jurisdictional High Court rulings. The Tribunal's finding was therefore neither contrary to the law then in force nor unsupported by the record, and no substantial question of law arose.

Conclusion: The subsequent amendment could not invalidate the Tribunal's decision; the issue is decided against Revenue.

Issues: Whether a reassessment notice issued before communication of the statutory sanction to the Assessing Officer was valid.

Analysis: The additional jurisdictional ground was admitted as it raised a pure legal question on facts already available on record. The sanction under Section 151 was communicated to and received by the Assessing Officer after the reassessment notice under Section 148 had been issued. The absence of a date on the approving authority's endorsement and the subsequent communication established that the notice preceded the effective communication of approval. Such prior issuance was a fundamental jurisdictional lapse, rendering the reopening and consequential reassessment invalid.

Conclusion: The notice under Section 148 and the consequential reassessment under Sections 143(3) and 147 were quashed as void.