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The High Court of Orissa directed the Appellate Tribunal to consider whether the penalty imposed under section 271(1)(a) of the Income-tax Act, 1961 was justified. The Tribunal cancelled the penalty citing the assessee's inability to file the return on time due to the firm's delay in finalizing accounts. The High Court upheld the Tribunal's decision, referencing the case of Venkateswara Power Rolling Mills. No costs were awarded.
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