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The High Court of Patna held that penalty under section 271(1) could be imposed even after serving notice under section 139(2) of the Income-tax Act. The Tribunal's view in favor of the assessee was deemed incorrect. The judgment favored the Revenue and directed the Appellate Tribunal to reconsider the penalty imposition. (Case citation: 1988 (1) TMI 22 - PATNA High Court)
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