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SC dismissed the appeal, affirming the High Court's dismissal of Revenue's challenge to the reopening of assessment. The SC held that directions to place on record the reasons to believe and the original order under s.143(3) were intended to test correctness of the CIT and Tribunal findings; Revenue's inability to produce the records precluded any demonstration that those findings were perverse in relation to the objections. In consequence, absent the relevant material, the CIT's conclusions, as affirmed by the Tribunal, were not amenable to interference. Although the High Court could have refrained from observing that Revenue was uninterested in pursuing the appeal, that remark did not vitiate dismissal.
SC dismissed the appeal, affirming the High Court's dismissal of Revenue's challenge to the reopening of assessment. The SC held that directions to place on record the reasons to believe and the original order under s.143(3) were intended to test correctness of the CIT and Tribunal findings; Revenue's inability to produce the records precluded any demonstration that those findings were perverse in relation to the objections. In consequence, absent the relevant material, the CIT's conclusions, as affirmed by the Tribunal, were not amenable to interference. Although the High Court could have refrained from observing that Revenue was uninterested in pursuing the appeal, that remark did not vitiate dismissal.
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