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The High Court of Calcutta upheld the penalty imposed under section 271(1)(a) of the Income Tax Act, 1961. The Tribunal found no valid reason for the delay in filing the return of income, concluding that the assessee had no sufficient cause for the delay. The Tribunal's decision was deemed fair and reasonable, with no error of law. The question was answered in favor of the revenue. No costs were awarded in this case.
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