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The High Court of Rajasthan ruled in a reference under the Income-tax Act, 1961 that no penalty under section 271(1)(a) was leviable against the assessee, a registered firm, for the assessment year 1978-79. The Tribunal's decision was upheld, stating that the firm had no tax liability as per the Explanation to section 271(1)(a). The reference was answered against the Revenue in favor of the assessee.
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