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The High Court of Punjab and Haryana overturned the Income-tax Appellate Tribunal's decision to delete a penalty under section 271(1)(c) amounting to Rs. 45,595. The Court found that the Tribunal did not consider the provisions of Explanation 1 to section 271(1)(c) correctly, which shifts the burden of proof onto the assessee. The appeal was allowed, and the penalty was reinstated by setting aside the Tribunal's order.
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