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Issues Involved: Appeal against High Court judgment quashing notices u/s 8/16 of Companies (Profits) Surtax Act, 1964.
Judgment Summary: Issue 1: Quashing of Notices u/s 8/16 of Companies (Profits) Surtax Act, 1964 The Supreme Court, in the present case, heard appeals challenging the High Court of Karnataka's judgment quashing the notices issued u/s 8/16 of the Companies (Profits) Surtax Act, 1964. After considering the arguments presented by both parties, the Court found no valid reason to interfere with the High Court's decision. The Court noted that several other High Courts had also taken a similar view in various cases, indicating a consensus in favor of the assessee. Therefore, the appeals were dismissed, affirming the High Court's decision to quash the notices. The Supreme Court cited precedents such as Addl. CIT v. Bimetal Bearings Ltd., Commissioner of Surtax v. Ballarpur Industries Ltd., CIT v. Dalmia Cement (Bharat) Ltd., and others, where similar decisions were made in favor of the assessee. The Court emphasized the preponderance of judicial opinion supporting the assessee's position, leading to the dismissal of the appeals. In conclusion, the Supreme Court upheld the High Court's judgment, dismissing the appeals and ruling that there would be no order as to costs.
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