Commissioner Of Income Tax vs G.M. Mittal Stainless Steel (P) Ltd.

The Supreme Court upheld the High Court's decision that the CIT's order under Section 263 of the IT Act was unjustified as the AO's treatment of the power subsidy as a capital receipt was based on an operative jurisdictional High Court decision. The Court emphasized that the CIT must have objective justification for deeming an AO's order erroneous, which was lacking in this case. Consequently, the appeal by the Revenue was dismissed, affirming the High Court's ruling in favor of the assessee.