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The High Court of Allahabad rejected the revenue's application under section 256 of the Income-tax Act, 1961. The Tribunal's decision was based on exceptional and unavoidable circumstances under rule 6DD(j) of the Income-tax Rules, 1962, including the assessee's new business, lack of market reputation, and cash-based transactions in the fertilizer industry. The Court found that there was sufficient material for the Tribunal's decision and no legal question arose for consideration.
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