UNION OF INDIA & ORS. vs SETH R. DALMIA

The Supreme Court held that the approval of the Central Government for the distribution of business by the Chairman of the Central Board of Direct Taxes does not need to be expressed in a formal order, as per Rule 4 of the Central Board of Direct Taxes (Regulation of Transaction of Business) Rules, 1964. The Court found that the High Court erred in disregarding affidavits confirming that the necessary approvals were obtained, thus validating the reopening of assessments under Section 148 of the Income Tax Act, 1961. The appeal was allowed, overturning the High Court's decision.