Allowing the appeal of the revenue the Court held that all that the Tribunal had done was to endorse the stand taken by the Commissioner (Appeals) and none of the grounds raised by the Revenue had been dealt with nor reasons assigned to show why the grounds canvassed by the Revenue were not tenable. The findings of the Tribunal, directly and substantially interfered with the interests of the Revenue and the finding were not based on the evidence brought on record by the Assessing Officer and the order of the Tribunal suffered from material irregularities, without any independent reasons. It had glossed over the relevant facts, which were brought on record by the Assessing Officer and therefore, the orders were perverse. The orders passed by the Tribunal were not valid. Followed Ajit Kumar (2018)  404 ITR  526 (SC), Santosh Hazari v. Purushottam Tiwari (2001) 251 ITR  84 (SC). (A Block period from 1997-98 to 2002-03, part of 2003-04)