How did the Supreme Court in Union of India v. Azadi Bachao Andolan (2003) treat the earlier decision…

In Azadi Bachao Andolan (2003), the Court agreed that "the decision in McDowell cannot be read as laying down that every attempt at tax planning is illegitimate". It also rejected the argument that an act otherwise valid in law can be treated as non est merely because of an underlying motive to save tax. McDowell was neither overruled nor treated as abolishing the Westminster principle.