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The Commissioner of Income-tax, Meerut applied under section 256(2) of the Income-tax Act, 1961 for two additions made to the income returned by the assessee for the assessment year 1986-87. The Income-tax Appellate Tribunal deleted the additions based on lack of evidence. The High Court rejected the application as the Tribunal's findings were based on facts and not on legal provisions, concluding that the application lacked merit and imposed costs of Rs. 150.
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