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The High Court of Allahabad ruled in favor of the assessee in a case involving penalties imposed under section 271(1)(c) of the Income-tax Act, 1961 for the assessment years 1967-68 and 1968-69. The Tribunal found that the assessee successfully rebutted the presumption arising from the Explanation to section 271(1)(c) and canceled the penalties. The court upheld the Tribunal's decision, citing lack of evidence to interfere. The judgment was delivered by B. P. JEEVAN REDDY C. J. and V. N. MEHROTRA.
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