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The ITAT Delhi-B judgment involved penalty proceedings under section 271(1)(c) for concealment of income for the assessment year 1989-90. The assessee filed a return showing a loss, which was reduced during assessment. The CIT(A) confirmed a penalty of Rs. 56.01 lakhs, canceling the balance amount. The tribunal cited a Punjab & Haryana High Court ruling stating that no penalty is leviable when the returned income is a loss. The penalty was canceled based on this, and the appeal filed by the Revenue was dismissed. The appeal by the assessee was allowed.
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