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The High Court of Allahabad ruled in favor of the assessee in a penalty proceeding under section 271(1)(c) of the Income-tax Act, 1961. The Tribunal found that the assessee had discharged the burden to rebut the presumption of underreported income. The court upheld the Tribunal's decision, stating that it was based on evidence and not perverse. The penalty was overturned, and the question was answered in favor of the assessee.
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