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The High Court of Allahabad was asked to provide its opinion on three questions related to the Income-tax Appellate Tribunal's decision. The Tribunal found that the assessee had successfully discharged the burden under Explanation 2 to section 271(1)(c) of the Income-tax Act, leading to the penalty being set aside. The High Court ruled in favor of the assessee and directed the case to be sent back to the Appellate Tribunal for further action.
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