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The High Court of Allahabad ruled in favor of the assessee in a penalty case for the assessment year 1964-65. The Tribunal canceled the penalty imposed by the Inspecting Assistant Commissioner as there was no gross negligence or fraud on the part of the assessee. The Tribunal's decision was based on factual findings, not legal presumptions. The court held that each case must be assessed based on its own facts and circumstances. The assessee was awarded costs of Rs. 200.
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