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The High Court of Allahabad held that the Inspecting Assistant Commissioner had no jurisdiction to levy penalty under section 271(1)(c) of the Income-tax Act after April 1, 1976, even if penalty proceedings were initiated before that date. The court's decision was based on the amendment of section 274(2) of the Act, which took away the Inspecting Assistant Commissioner's jurisdiction to pass penalty orders. The judgment favored the assessee and ruled against the Department.
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