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The High Court of Kerala granted a certificate of fitness for appeal to the Supreme Court under section 261 of the Income-tax Act, 1961. The appeal concerns the validity of a reference under section 274(2) to the Inspecting Assistant Commissioner based on divergent views in the majority and minority judgments. The court considered the factual matrix and issued the certificate for appeal due to the substantial question of public importance regarding the pending penalty proceedings before the Inspecting Assistant Commissioner.
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