COMMISSIONER OF INCOME-TAX, WEST BENGAL CALCUTTA vs CALCUTTA DISCOUNT CO., LTD.

The Supreme Court held that the Appellate Tribunal's dismissal of the Income-tax Officer's appeal on procedural grounds was incorrect, emphasizing that the Tribunal should focus on the substance of the matter rather than technicalities. The Court affirmed the Appellate Assistant Commissioner's view that the assessee could arrange its affairs to minimize tax liability, as long as it did not involve secret profits. The appeal was dismissed, upholding the legality of the transaction between the assessee and its subsidiary under the Income-tax Act, 1922, specifically referencing Section 66(1).