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The High Court of Delhi heard cross-applications by the assessee and the Commissioner of Income-tax regarding the applicability of section 147(a) of the Income-tax Act, 1961 for the assessment year 1971-72. The Tribunal found that the assessee did not fully disclose necessary facts during the original assessment. The Tribunal directed the allowance of Rs. 1,00,000 in the assessment year 1972-73, which the Department contested as the Tribunal only had jurisdiction over the 1971-72 assessment. The High Court directed the Tribunal to refer the question of law regarding the Tribunal's jurisdiction. The applications were disposed of with no costs.
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