Madanlal Patodia vs Commissioner Of Gift-Tax

The Supreme Court held that the High Court erred in its factual basis not supported by the Tribunal's order, which is the final fact-finding authority. The Court emphasized that the decision in Bharat Hari Singhania v. CWT was not argued before the High Court and was unknown to the assessees. Consequently, the Court allowed the appeals, set aside the High Court's order, and restored the reference for fresh hearing, permitting both parties to present their contentions.