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The High Court of Madras considered a case regarding the levy of a penalty under section 28(1)(c) of the Indian Income-tax Act on Hariram Sait for the assessment year 1943-44. The court found that Hariram Sait was not personally responsible for concealing income, as it was mainly done by his deceased father Sokkalal. Therefore, the court ruled in favor of the assessee, stating that there was no basis for the penalty imposed on Hariram Sait.
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