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The High Court of Allahabad considered an income-tax reference regarding the jurisdiction of the Inspecting Assistant Commissioner to impose a penalty under section 271(1)(c) after April 1, 1976. The Tribunal's decision was based on a previous court ruling that was later overturned by the Supreme Court. The High Court set aside the Tribunal's order and remanded the matter for a fresh decision in light of the Supreme Court's judgment.
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