Commissioner Of Income Tax & Ors vs Chhabil Dass Agarwal

The Supreme Court upheld the High Court's decision to quash the assessment orders under Section 148 of the Income Tax Act, 1961, for the Assessment Years 1995-1996 and 1996-1997. The Court found that the income of a non-Sikkimese residing in Sikkim is not taxable under the Act, particularly in light of the insertion of Section 10(26AAA) which exempts certain incomes for Sikkimese individuals. The Court emphasized that the assessing authority's actions were not in accordance with the amended provisions and instructions issued by the Central Board of Direct Taxes.