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The High Court of Madras upheld the Tribunal's decision that the addition to income was not justified. The court ruled that the Commissioner's revision of assessment based on failure to initiate penalty proceedings was unsustainable. The court cited a Delhi High Court case to support this view. The court concluded that the Tribunal was correct in setting aside the Commissioner's order under section 263 of the Income-tax Act for the assessment year 1984-85.
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