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The Bombay High Court ruled that mens rea is not essential for penalty under section 271(1)(a) of the Income-tax Act. The court also held that interest under section 139 is linked to penalty under section 271(1)(a). The case involved an assessee company for the assessment year 1970-71, where penalty was imposed for late filing of returns despite extensions granted. The court cited a Supreme Court decision in support of its ruling. The court did not address questions 1 and 3.
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