COMMISSIONER OF INCOME TAX, MUMBAI vs BHUPEN CHAMPAK LAL DALAL & ANR.

The Supreme Court ruled that criminal proceedings under the Income Tax Act, 1961 can continue independently of pending appeals before the Income Tax Appellate Tribunal. However, it established that if the appellate authority's findings are relevant to the criminal case, the criminal court may stay proceedings until the appeals are resolved. The Court upheld the principle that the outcomes of tax assessments can influence criminal liability, as seen in G.L.Didwania & Anr. vs. Income Tax Officer, 1995 Supp.(2) SCC 724, and emphasized the need for judicial consistency between civil and criminal proceedings.