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The High Court of Allahabad rejected the Commissioner of Incometax's application to direct the Income-tax Appellate Tribunal to state the case on various questions related to penalty under section 271(1)(c). The dispute involved three additions, with the first addition voluntarily offered by the assessee and the other two additions explained by the assessee but rejected by the Income-tax Officer. The court found that the questions proposed were not questions of law and rejected the application.
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