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The High Court of Allahabad ruled that the Income Tax Officer had jurisdiction to impose a penalty in cases where the concealed income was below Rs. 25,000. The Tribunal's decision to set aside the penalty order was overturned, and the case was remanded for consideration on merits. The questions of law were answered in the negative, in favor of the department and against the assessee. The Commissioner was awarded costs of Rs. 200.
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