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The High Court of Bombay considered two questions referred by the Income-tax Appellate Tribunal regarding penalty orders under section 271(1)(c) of the Income-tax Act, 1961. The court found that the date of reference by the Income-tax Officer to the Inspecting Assistant Commissioner was crucial in determining the validity of the penalty orders. Since the date of reference was not provided, the first question was left unanswered, and consequently, the second question was not addressed. The reference was returned unanswered with no order as to costs.
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