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The Tribunal held that the loose sheets alone, without corroborative material, were insufficient to form the basis for reassessment. The Court found that the sanctioning authority had not applied its mind independently, leading to a mechanically granted approval.
The Tribunal held that Section 40(a)(ia) of the Income Tax Act cannot be applied to cases of short deduction of tax at source. The High Court upheld this finding, following the principle that in case of divergent views of non-jurisdictional High Courts, the view favorable to the assessee should be preferred.
The Tribunal answered the questions of law regarding assessability under Section 44BB against the Revenue. For Section 234B, the matter was remitted back to the Assessing Officer for reconsideration.